We recently went through an FDIC Safety & Soundness exam and I'm very curious about something. It was strongly recommended that we add the volume of CTRs and employee turnover to our risk assessment. Just wondering if anyone else includes this?
Thanks!!

I include the CTR volume and the turnover rate for tellers in my BSA/AML Risk Assessment. I also include if there was any turnover in the Senior Management Group.

I work at a 14 branch community bank which is examined by the FED.

Both the quantity of large currency transactions and the turnover of key personnel are risk factors listed in the matrix in Appendix J to the BSA Exam Manual. The guidance for that appendix says that "Examiners should use the following matrix, as appropriate, when determining the quantity of BSA/AML risks."

Thank you both!

CTR volume is important to know since the cash flowing through, the greater the risk. However, don't just count the CTR's - count the DIRECTION of the cash - i.e. do you have more large cash deposits or large cash withdrawls? Your risk is a little different if you find that most of your CTR's are filed for cash withdrawals from accounts that have a direct payroll deposit vs. large deposits of cash from folks you have know idea where they're getting that kind of money.

As for employees, your risk runs higher if you have a lot of turnover since that means you really have to increase your training frequency to bring newbies up to speed.