Should all retail stores be listed as high risk for the BSA risk assessment? Any thoughts are appreciated. Thank you.

We have them listed as our first tier of high risk customer because of their cash industry. If they misbehave (structuring or other suspicious activity) or perhaps because of being in a particular location like a HIDTA or HIFCA) they get moved to our higher tier of high risk.

I started off putting all retail as high risk in a category called Cash Intensive - Retail with the highest risk code, but in reality alot of them don't bring in a lot of cash, so I recently created another category - Non Cash Intensive - Retail with a lower risk rating.
Of course, as Kaybee states, if any activity occurs such as increased cash volumes or suspicious activity, it would get kicked up to the higher risk rating.
Hope this helps you.

We are in the process of doing all our risk codes on our customers, and just came up with Low and High risk, based on the list by the OCC. Was wondering if you would share how you would break them down even more besides the cash intensive issue? Thanks!

A higher risk list could take many forms based upon your bank:

location of branch (in a HIDTA or HIFCA)
amount of cash transacted by customer
very high risk industry (check cashers, money transmitters, etc.)
Industries your bank has particular problems with (MSBs, used car dealers)
previously filed SARs
non-resident aliens (may need additional monitoring for wire activities)

These are just examples. The actual list will depend upon your bank.

You rock!!! Thanks!

The Professional Bank Services AML/BSA manual has an excellent example of a risk assessment matrix and risk scoring model that I am using right now to create my own risk assessment. I attended their seminar last month and it was excellent, the manual is a great refference tool.

What is the web site for Professional Bank Services? I'd like to find out more about these risk assessments as I am redoing our own.

Here it is, you can just buy the manual online if you wish.