You know, after reviewing a lot of material on BSA Risk Assessment, etc., etc., blah, blah, and blah, the thought occured to me:
The idea behind conducting a bank wide BSA Risk Assessment is not unlike the idea of establishing a Performance Context for CRA.
Think about it - you are establishing the backdrop against which your BSA/AML/OFAC performance will be measured. Which areas require additional attention? Which areas have enough in place? Not unlike credit needs assessment and what is already covered to death by your peers in CRA.
Well - what can I say? A few days of freedom, and the mind starts to wander......
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CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'