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#2050321 - 11/18/15 06:34 PM UIGEA Risk Assessments?
vsb2211 Offline
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Joined: Jul 2009
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New item we have seen in an FDIC audit is "Risk assessments for UIGEA (Unlawful Internet Gambling Enforcement Act)." It wasn't on our State Exam last year and it wasn't on the FDIC exam in 2012. Not sure what they want, anybody have anything they would like to share in this regard?

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#2050324 - 11/18/15 06:37 PM Re: UIGEA Risk Assessments? vsb2211
vsb2211 Offline
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Joined: Jul 2009
Posts: 8

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#2050843 - 11/21/15 11:28 AM Re: UIGEA Risk Assessments? vsb2211
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
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The examination procedures instruct examiners to review the UIEGA risk assessment. That means if you have one, they need to look at it. It does not mean you are required to have one.

There simply is no realistic way to assess the "risk" at the bank level. Customer by customer, maybe.
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