BSA-AML Examiner School Case Study eBook

Office of Foreign Assets Control Risk Assessment Please check one of the following for each category:

Low Stable, well-known customer base in a localized environment. Low X Few high-risk customers; these may include nonresident aliens, foreign customers (including accounts with U.S. powers of attorney) and foreign commercial customers. Low X No overseas branches and no correspondent accounts with foreign banks. Low No electronic banking (e- banking) services offered, or products available are purely informational or non- transactional.

Moderate X Customer base changing due to branching, merger or acquisition in the domestic market. Moderate A moderate number of high- risk customers.

High A large, fluctuating client base in an international environment. High A large number of high-risk customers.

Comments See above for explanation of customer base.

Comments

Moderate Overseas branches or correspondent accounts with foreign banks. Moderate X The bank offers limited e- banking products and services (i.e., internal account transfer and e-bill payment).

High Overseas branches or multiple correspondent accounts with foreign banks. High The bank offers a wide array of e-banking products and services (i.e., account transfers, e-bill payment, or accounts opened via the Internet).

Comments

Comments See above for online and mobile banking explanation.

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