BSA/AML Risk Assessment Best Practices

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An effective BSA/AML/OFAC risk assessment is one that assists a financial institution in identifying inherent risks, the control environment and residual risk in order to identify the institution’s risk profile. As stated in the FFIEC Examination: “Understanding the risk profile enables the bank to apply appropriate risk management processes to the AML/compliance program to mitigate risk. There are many different types of risk assessments that are suitable. Financial institution management should identify the method or format best suited to identify their specific risk profile.

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Description

Description

An effective BSA/AML/OFAC risk assessment is one that assists a financial institution in identifying inherent risks, the control environment and residual risk in order to identify the institution’s risk profile. As stated in the FFIEC Examination: “Understanding the risk profile enables the bank to apply appropriate risk management processes to the AML/compliance program to mitigate risk. There are many different types of risk assessments that are suitable. Financial institution management should identify the method or format best suited to identify their specific risk profile.

Objectives of the Presentation

 Basis for the Risk Assessment
 Understanding Customer Risk
 Understanding Products & Services Risk
 Understanding Geographical Risk
 Secondary Risks
 Institution’s Trending
 Preparing the report

Why Should you Attend

The risk assessment process should be considered a living process. According to the FFIEC Examination Manual: “An effective BSA/AML compliance program controls risks associated with the bank’s products, services, customers, entities, and geographic location; therefore, an effective risk assessment should be an ongoing process, not a one-time exercise. Management should update its risk assessment to identify changes in the bank’s risk profile, as necessary (e.g., when new products and services are included, existing products and services change, higher-risk customers’ open and close accounts, or the bank expands through mergers and acquisitions). Even in the absence of such changes, it is a sound practice for banks to periodically reassess their BSA/AML risks at least every 12 to 18 months.”

Areas Covered

 The risk assessment process
 Risk factors to consider addressing
 Developing the financial institution’s BSA/AML program based upon its risk assessment
 Updating the risk assessment
 Rating methodologies
 Qualitative v. Quantitative

Who will Benefit

 Chief Compliance Officers
 BSA Officers
 Risk Officers
 Auditors

 

Instructor Profile:
William Schlameuss has over 20 years’ experience in regulatory compliance, including BSA/AML/OFAC. He has worked with a wide range of US branches of major foreign banking organizations from all continents, both as chief compliance officer and compliance consultant. He has a prior background in IT as manager and implementer of core banking and payment systems, as well as compliance-related systems.

Mr. Schlameuss has extensive experience with State and Federal Banking regulators in examination preparation, assistance and response, including assistance in the remediation of written agreements for clients. As a project manager Mr. Schlameuss has led BSA/AML audits, BSA/OFAC Model Validations, remediation efforts of BSA audit issues , and BSA/OFAC look-backs for international banks, both self-imposed and directed by regulatory authorities. Model Validations included Prime, FCRM, Patriot Officer, Actimize, and eGIFTS.

He has conducted the Annual 3130 Supervisory Reviews for Broker-Dealers of the US branches of major FBOs. Mr. Schlameuss is also a member of the Association of International Bank Auditors and the International Bank Regulatory Compliance Committee.

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