Banking Bad? A Global Mystery Shopping Test of the Risk-Based Approach

Banks and corporate service providers are meant to apply a risk-based approach to customer due diligence, yet no one really knows if they do in practice. To test this proposition, a global 'mystery shopping' exercise based on thousands of solicitations for companies and corporate bank accounts was conducted. Those doing the shopping were a mix of real shell companies and fictitious consultants we created to personify various risk profiles, from corruption to terrorist financing. The design of our study allowed us to measure the effect of different kinds of risk on the likelihood that firms would do business, and on their propensity to follow or flout international know-your-customer rules.


  • Ian Huddleston TEP, Chair of the Professional Standards Committee, STEP Worldwide


  • Professor Jason Sharman, University of Cambridge, UK

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