Introductory BSA/AML Examiner School, Atlanta, CA

Risk Assessment

Risk Assessment – BSA Program Interaction

Management’s understanding of risk determines the construction of the five pillars.

1. type and extent of internal controls , 2. scope of independent testing , 3. skills and expertise of the BSA Officer , 4. focus and approach of training . 5. beneficial ownership (May 11, 2018)

7

BSA/AML Compliance Program Risk Assessment

Risk Assessment

Internal Controls

Identify & Measure Risk:

Develop Applicable:

• Products

• Policies

• Services

• Procedures

• Customers

• Systems

• Geographic locations

• Controls

Result:

Risk-Based BSA Compliance Program

• Internal controls

• Audit

• BSA compliance officer

• Training

8