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Numerous banks have been the subject of public BSA enforcement actions within the past year and one common theme throughout these public, written actions was either the lack of, or deficiencies associated with, the subject bank’s BSA Risk Assessment. There is no mandatory requirement to conduct a BSA Risk Assessment, within the FinCEN or agency BSA regulations, but risk assessments are the second topic addressed in the BSA/AML Examination Manual and the strength of the language in the examination manual makes it easy to determine that a comprehensive, risk-based assessment will be the focal point of a bank’s BSA examination.
The examination manual states that the risk assessment topic was given its own section in the manual to “emphasize its importance ….in the bank’s design of risk-based controls. Let’s all heed the examiners strongly worked advice on this issue.
The manual points out that there are many effective methods and formats used for BSA risk assessments and this webinar will assist your bank in determining what formation might be best from both a cost and regulatory expectation point of view. This program will identify the regulatory guidance directed at banks and the BSA risk management methodologies utilized by regulatory agencies.
A risk assessment is the first step in determining the focus and parameters of the bank’s BSA monitoring program as well as determining the scope and coverage of its compliance audit program. You’ll receive a detailed manual that will serve as a vital resource in developing or enhancing the bank’s BSA risk assessment program.
Upon completion of the program participants understand regulatory expectations regarding:
- Which levels of management, business units, and appropriate staff should be involved in the BSA risk assessment process including report distribution;
- How to write a report that provides a comprehensive analysis in a concise and organized presentation;
- Determination of Step 1 categories such as products, services, customers, entities, transactions, entities, geographic locations, etc;
- Steps 2 data necessary for a detailed analysis to assess Step 1 risk categories;
- The level of metrics needed in your risk assessment and comparison of such metrics on a year-over-year or quarterly manner;
- Independence and knowledge level of personnel performing the risk assessment;
- Development of framework for scoping, identifying, assessing, testing, monitoring, and reporting; and
- What should be documented and reported versus addressed informally.
The program is designed for BSA Officers, Compliance Officers, Risk Officers, Auditors and supporting staff members.