I agree. Monthly reviews seems excessive unless these are extremely high-risk such as MSBs or something. I am now at my second bank as BSA/AML Officer under 500m in assets. We conduct high-risk reviews annually. I've designed my own review process over the years. Develop your own process and stick with it. Make sure to compare data/activity over that time period, year over year/quarter over quarter/etc. When I came here about 6 months ago, I re-wrote our risk-assessment, changed the reviews from quarterly to yearly, wrote new policies and procedures. Make the program your own. You don't need to follow what the previous CO used, it's your program now, make it yours.