I am trying to develop a BSA risk assessment on my bank. I am new in banking. I have been my bank's internal auditor for about 6 months. Was wondering if anyone could provide any guidance on developing a BSA risk assessment. We have completed an overall risk assessment for the bank, but not a specific BSA risk assessment. Any help would be appreciated!

Madionne
There has been alot on the topic - try doing a search in Bankers Threads, and also go to Bankers Tools on BOL.

You might also refer to Appendix J of the June 30, 2005 BSA Examination Manual.

I have also used the appendix J from the FFIEC BSA/AML manual and added items that I felt were important for my bank. This way it is also tailored.

Jennifer

Welcome to BOL!

As noted, appendix J to the current examination procedures is your template and the examination procedures themselves will provide some guidance on how the risk assessment will be used. (Search them using "risk assessment.") The examination procedures are expected to be updated this month with a number of "improvements" including expanded guidance on the risk assessment. If you sign up for "BOL Briefings" (lower left of BOL's home page) you will be notified when they are published.

If you use the Bankers Threads "search" feature (top of this page) using keywords "risk assessment," search only this forum, and go back no more than one year, the search will stop when it reaches 200 posts mentioning that term. However, those discussions are understandably random and your best starting point would probably be the BSA Risk Assessment tools Brenda C contributed in Bankers Tools.

Finally, BOL has offered webinars on the subject, the most recent of which was last month. It can be ordered through the Training Catalog.

If your role in audit includes performing the independent review of BSA compliance, you will disassociate yourself from the BSA risk assessment process now. One of your responsibilities will be to review the risk assessment for its scope, accuracy, etc. If you participate in developing it, you are no longer an independent source of review.

Are you saying that if we are going to be performing the BSA compliance audit then we should not prepare the risk assessment?? If this is true, who should prepare the risk assessment? Should it be our BSA officer? We (internal audit)were given this task by our CFO due to an external review of our BSA program that happened last October. One of their recommendations was that we have no BSA/AML risk assessment and we needed to develop one. Thanks!

Your BSA Officer, working with the business units/products,should be preparing the risk assessment.

Kaybee's suggestion for the members of the group who should do it is good and it may be subject to amendment or improvement by others. However, the person or group that cannot be involved are those responsible for doing the independent examination.

Imagine the reaction of a friend of mine who makes his living doing independent BSA audits when he realized this after doing several risk assessments for client banks. He just blew himself out of the water for next year's audits, much larger billable projects.

Thanks for all your help!!

Last year I moved into the compliance area as the BSA officer. The training mentioned in Ken's email has been the best job tool I have had. Normally I order the CDs- anything about MSBs, risk assessments, etc.. Now when I look at my banks risk assessments, CDD/EDD procedures, etc.. I am just amazed that I understand most of what I'm reading!And I am the person who actually documented it! Thanks BOL!

We recently had a BSA exam and I used BOL's model for the risk assessment, just tweeked it for our bank. The examiners thought it was very well organized and covered the topics needed. Thanks BOL!