Please help! I am looking for a canned way to introduce the concept of doing BSA and OFAC Risk Assessments to our line managers. It needs to be very simplified and easy to follow. It does not necessarily need to be geared to BSA and OFAC specifically, but will need to allow them to assess their areas for the levels of BSA/AML/OFAC inherent in what they do.

Thoughts?

The Expanded Overview of types of products and services in the new exam procedures may be a good place to start with your line managers. Each section includes a discussion of risk factors inherent in each product or service.

Yes, that is exactly where I was going to start (I have read the whole thing). Unfortunately, in bringing my manager up to speed on the subject, I lit a fire and now need to have something ready for next Wednesday's manager's meeting!

Lots of interesting administrative actions by the various regulators against banks. Scary to read some of the agreed upon corrective actions. Really a good reason for everyone to get their BSA in shape.

Many banks are delegating the analysis to their individual business lines and then developing a composite analysis. For a complex institution, it is probably the only realistic approach. It also not only educates the managers on the risks involved, it's abundantly clear to them that if the analysis is flawed they will be held responsible.

Banks that do this generally begin with a training session where they bring the units up to speed on the issues. Then they distribute questionaires that track Appendices J and M in the interagency examination procedures. The managers of the business lines complete their reports and return them to the BSA Officer who analyzes them for credibility. When the process is completed, the BSA officer compiles a bank wide risk assessment.

You won't build the documentary structure for this between now and Wednesday unless someone here just decides to donate their work product. My suggestion is that you hand out a memo describing the risk assessment overall, include a time table for the steps leading to its completion, provide copies of the matrices and see what questions people have in advance.