Updating Your BSA/AML/OFAC Risk Assessment

Presented by:
Ken Golliher

Are you looking for an efficient, focused approach to updating and critiquing your BSA, AML and OFAC risk assessments? Here it is!

WHAT?
Banks are expected to conduct routine risk assessments regarding the "quantity" of risk their institution incurs in relation to Bank Secrecy Act compliance as well as their exposure to money laundering and terrorist financing. An OFAC compliance risk assessment is also expected. In both cases, the assessment must be documented; i.e. in writing. These assessments have a relatively short life expectancy, generally 12 to 18 months. Examiners and independent auditors will request a copy of the current version at the inception of on-site BSA/AML examinations. This webinar shows participants how to gather the necessary information and develop an appropriate document that serves as a valuable resource for their institution. Perhaps of more importance, it focuses on how banks can build a structure that makes the reviews and updates easier by creating a data base of relevant information from prior reviews. It also has a section on how to use board reports to keep the board abreast of relevant risk related information throughout the year.

WHY?
Indicating comprehension of the old adage, "If you don't know where you are going, any road will take you there," regulatory agencies expect financial institutions to fully identify their BSA/AML/OFAC destination before they implement a compliance program. In short, they start with the principle that it's impossible to design an appropriate compliance effort unless the financial institution has objectively evaluated its situation.

An effective risk assessment is both a sword and a shield for financial institutions. It helps them to focus limited resources on the areas where they are likely to do the most good. It also allows financial institutions to explain why they have chosen not to implement compliance mechanisms that outside evaluators have seen elsewhere.

PROGRAM CONTENT
The presentation focuses on identifying and analyzing the necessary information and developing a document that supports the financial institution's decisions. It addresses product, service, customer and geographic risk. Content includes:

operational considerations.

SAMPLE ASSESSMENT
The program materials include a sample risk assessment. It is not a "one size fits all" document that financial institutions can adopt as their own. On the contrary, it's a teaching tool that is intended to illustrate that, while some elements are common to all risk assessments, each financial institution has to invest its own time and effort into developing an accurate assessment. Nevertheless, attendees at prior seminars who modeled their efforts after the approach outlined above have consistently reported that their regulatory agencies and independent examiners were well satisfied with the approach. (Attendees at Ken's webinars are always very complimentary of the sample documents and language he includes in his materials.)

The program is designed as an update for experienced BSA officers and auditors employed by banks, thrifts and credit unions. It is not designed as a general review or to meet the needs of other types of financial institutions. This presentation is substantially similar to a highly rated offering at the BOL BSA Top Gun School. Attendees at that event need not register unless they want other members of their committee to hear the presentation.

The Speaker:
Ken Golliher is a principal with Pegasus Educational Services, LLC, a training firm headquartered in Louisville, Kentucky. He is an experienced banker with a unique ability to reduce complex legal concepts to plain English. He has explained the "why" and "how" of regulations to thousands of financial institution personnel and examiners. Ken's banking career began in 1972 and includes serving as a teller, commercial operations manager and as trust department legal counsel in a state and a national bank. For ten years he headed the education division of a regional consulting firm for financial institutions. He has served on the faculty of the LSU Graduate School of Banking, the OTS' Level I Compliance School and the FDIC's Advanced Consumer Protection School for examiners. He has presented seminars in more than 25 states and has served as an instructor at compliance schools sponsored by the Illinois, Indiana, Georgia, Kansas, Kentucky, Nebraska, Pennsylvania and Texas bankers associations. He is one of the moderators for the Bank Secrecy Act forum at http://www.bankersonline.com

VIEW A 10 MINUTE SAMPLE
(requires Windows Media Player and IE).

• Complete presentation (including slides and audio)
• Written Materials
• Follow-up Q & A

You have the right under this license agreement for this CD-ROM to use this presentation on a single-workstation. Use on a network is in violation of the copyright agreements. CD may be used by multiple users at a given institution but may not be placed on a network or in any other multi-user environment.