The risk assessment process should be considered a living process. According to the FFIEC Examination Manual: “An effective BSA/AML compliance program controls risks associated with the bank’s products, services, customers, entities, and geographic location; therefore, an effective risk assessment should be an ongoing process, not a one-time exercise. Management should update its risk assessment to identify changes in the bank’s risk profile, as necessary (e.g., when new products and services are included, existing products and services change, higher-risk customers’ open and close accounts, or the bank expands through mergers and acquisitions). Even in the absence of such changes, it is a sound practice for banks to periodically reassess their BSA/AML risks at least every 12 to 18 months.”
An effective BSA/AML/OFAC risk assessment is one that assists a financial institution in identifying inherent risks, the control environment and residual risk in order to identify the institution’s risk profile. As stated in the FFIEC Examination: “Understanding the risk profile enables the bank to apply appropriate risk management processes to the AML/compliance program to mitigate risk. There are many different types of risk assessments that are suitable. Financial institution management should identify the method or format best suited to identify their specific risk profile.
This insightful session will discuss the following points:
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