Our bank offers NDIP products through a third party who works with a broker/dealer. They are not affiliated with us in any way and we just refer our customers over the third party.

Any BSA requirements here and can I exclude from my risk assessment?

First of all I believe that documentation is the key to any risk assessment. You should document your mitigating factors and control processes. For example, how do they pay for these products? If a customer brought in cash, could they get a non-investment product. Then you may want to touch base with this third part and determine what they do or don't do to prevent or review accounts for money laundering.

At our bank we have those products, but it took me a lot of work to feel comfortable with them.