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#1766073 - 12/11/12 06:53 PM BSA Risk Assessment - annually?
complyami Offline
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complyami
Joined: Feb 2003
Posts: 134
Is it required by guidance or regulators that an OFAC,BSA,CIP risk assessment be preformed annually?

We are low/moderate risk in all areas and do complete one annually, but I can't find where that is stated in the guidance as a requirement.

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BSA/AML/CIP/OFAC Forum
#1766078 - 12/11/12 06:58 PM Re: BSA Risk Assessment - annually? complyami
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 82,469
Galveston, TX
The top of page 29 in the exam manual:

Even in the absence of such changes, it is a sound practice for banks to periodically reassess their BSA/AML risks at least every 12 to 18 months.
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#1766082 - 12/11/12 07:01 PM Re: BSA Risk Assessment - annually? complyami
complyami Offline
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complyami
Joined: Feb 2003
Posts: 134
Thank you, much appreciated smile

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#1766183 - 12/11/12 08:40 PM Re: BSA Risk Assessment - annually? complyami
QCL Offline
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QCL
Joined: May 2002
Posts: 6,259
NW IL
And if you are a national bank, use your MLR data to validate your Risk Assessment.

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#1767448 - 12/14/12 02:19 PM Re: BSA Risk Assessment - annually? complyami
BrendaC Offline
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BrendaC
Joined: Sep 2001
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Sweet Home AL
Reminder - don't wait 12-18 months if you change services (particularly add a higher risk service such as Trust) or expand your market territory.
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