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#1995478 - 02/11/15 10:03 PM Risk Assessment & OFAC
PrimeTime Offline
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PrimeTime
Joined: Nov 2014
Posts: 173
I've seen two schools of thought in regards to the Risk Assessment and its relation to OFAC, and I was looking to find out what other members of this site are doing.

Some information I've read says that the OFAC Risk Assessment can be included in the BSA/AML Risk Assessment, however other sources state that they need to be separate. I'm wondering if this is based off institution size, as well as risk appetite.

I'm from a moderate size community bank, only located in 2 states, and have what I believe to be an extremely low amount of risk. As a result, I think it's completely feasible to include the OFAC risk assessment as a section of the BSA/AML risk assessment, however I didn't want to get slammed by the examiners for doing so.

Thoughts? Examples? Feedback is much appreciated!
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#1995481 - 02/11/15 10:10 PM Re: Risk Assessment & OFAC PrimeTime
Doug Hendrickson Offline
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Doug Hendrickson
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We have one BSA/AML/OFAC risk assessment document. One section has the risks for BSA/AML and the second section has the risks for OFAC. We've never had a problem with them both being in the same document.
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#1995506 - 02/11/15 11:55 PM Re: Risk Assessment & OFAC Doug Hendrickson
Cape Codder Offline
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Same here.
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#1995512 - 02/12/15 12:42 AM Re: Risk Assessment & OFAC PrimeTime
Greg Offline
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Joined: May 2004
Posts: 833
Michigan
I have them in one document but they are not combined. Each is presented as a distinct risk statement.
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#1995529 - 02/12/15 01:41 PM Re: Risk Assessment & OFAC PrimeTime
New Manager Offline
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Same here and at my last two jobs.

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#1995535 - 02/12/15 02:06 PM Re: Risk Assessment & OFAC PrimeTime
happyauditor Offline
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happyauditor
Joined: Nov 2004
Posts: 809
NY
Our regulatory examiner "suggested" (aka required) we make the risk assessments separate and also to make our audits separate (even though when both the risk assessment and audit was incorporated within the BSA risk assessment and BSA audit, they did not have any comments on either being deficient.)
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#1995565 - 02/12/15 03:08 PM Re: Risk Assessment & OFAC PrimeTime
PrimeTime Offline
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PrimeTime
Joined: Nov 2014
Posts: 173
Awesome! Thanks for the feedback everyone. Maybe it was the wording that was giving me the confusion, they can be "combined" into the same document, but a SEPARATE risk assessment needs to be performed on each.
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#1997492 - 02/23/15 02:06 PM Re: Risk Assessment & OFAC PrimeTime
P*Q Offline

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P*Q
Joined: May 2001
Posts: 8,439
Somewhere
One document but risk assessed separately.

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