Criminals can use complex structures as a way of obscuring the source of funds in a transaction or their ownership. If the matter involves creating a complex structure, it is important that you consider if there is a genuine purpose for this. Complex structures can be used to launder money or disguise ownership. Your assessment of whether a structure is unusual or unduly complex should be based on the risk of money laundering that it poses. You should consider what you know about the client, the client’s business, if the matter is in line with your previous dealings with the client and if it makes sense for the transaction to be structured in this way. Your considerations should be documented on the risk assessment.