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#380612 - 07/05/05 04:00 PM Risk analysis/assessment
Anonymous
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Is the bank's overall BSA/AML risk assessment required to be included in the board approved policy?

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BSA/AML/CIP/OFAC Forum
#380613 - 07/05/05 04:56 PM Re: Risk analysis/assessment
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
I have it as a stand alone document.

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#380614 - 07/05/05 05:03 PM Re: Risk analysis/assessment
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
Whether or not it is included in the BSA policy or is a stand alone document, I assume that it needs to be Board approved, correct? Also, once it is completed and approved, what next? If the BSA policy that is in place is robust, thorough, etc, should the risk assessment necessarily change anything in the policy?

Thanks you your thoughts.

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#380615 - 07/05/05 05:20 PM Re: Risk analysis/assessment
Maya Offline
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Joined: Jan 2005
Posts: 154
South Carolina
I am attempting to start the risk assessment process but I am having a "compliance block" in getting my thought process started. Can you point me in the right direction with any thoughts or ideas? Thanks.

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#380616 - 07/05/05 05:45 PM Re: Risk analysis/assessment
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Mine was not Board approved. It was reviewed and approved by a BSA/High Risk committee. The risk assessment that I did dictates the site visits that would be required for the high risk accounts, so it was shared with the retail area.
I take the highest risk accounts and assign each quarter of the year for site visits by the retail staff.
e.g. 1st Quarter - all cash intensive customers must be visited and a Site Visit Report completed.
2nd Quarter - all International wire customers, etc.
I realise this works for small banks and larger banks will have to be more creative.
I 'exempted' or placed in the lowest risk category, those customers who are very well known to the bank and those with whom the bank has regular contact with.
The officers in charge of those accounts had to give me the names of these customers and state that they maintained regular contact and that they understood their business.
I figured it was a start to the process!

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#380617 - 07/05/05 08:25 PM Re: Risk analysis/assessment
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
Magic, I am a bit confused. I understood the original posting to be concerning the overall risk assessment for the bank (see page 18 of the new exam procedures, as well as appendix J) while your reply seems to be about specific customers.

Am I misunderstanding anything? Thanks.

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#380618 - 07/05/05 10:03 PM Re: Risk analysis/assessment
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
The original poster had a What Next question - once the bank assessment is done.
The number of high risk accounts you have and the type of high risk accounts you have is a determining factor in the overall analysis.
After doing the overall analysis, I took the high risk accounts as determined by the OCC and others deemed high risk by the bank, and risk assessed them with actions to be taken by the bank, based on the risk, such as site visits, to ensure that the bank 'knows the customer' and has at least annual or semi-annual contact with the customer.
In other words, once the bank assessment was done, I took the factors that were high risk and addressed how we would handle each high risk factor.

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