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Management must structure the lender’s BSA/AML compliance software to adequately deal with its hazard profile, as determined by the danger assessment. Management must have an understanding of the financial institution’s BSA/AML threat exposure and build the suitable procedures, strategies, and processes to observe and Manage BSA/AML challenges. For example, the bank’s checking units to recognize, study, and report suspicious action needs to be risk-centered, with specific emphasis on bigger-hazard solutions, products and services, prospects, entities, and geographic areas as determined because of the bank’s BSA/AML danger assessment. Unbiased testing (audit) should really evaluate the financial institution’s threat assessment for reasonableness.

Financial institution administration really should come to a decision the suitable system or structure, based on the bank’s certain hazard profile. Whatever format administration chooses to use for its hazard evaluation, it should be very easily comprehended by all ideal events. The development in the BSA/AML possibility evaluation frequently entails two steps: initially, discover the particular hazard types (i.e., merchandise, expert services, customers, entities, transactions, and geographic spots) one of a kind to your lender; and next, conduct a more in-depth Examination of the info identified to better evaluate the risk in these classes. In reviewing the danger assessment in the scoping and organizing method, the examiner should really determine irrespective of whether administration has considered all goods, companies, buyers, entities, transactions, and geographic locations, and irrespective of whether management’s specific analysis inside of these unique chance categories was enough. Should the bank has not made a risk evaluation, this reality ought to be talked about with management. For that needs of the examination, When the bank hasn't accomplished a risk assessment, or the chance assessment is inadequate, the examiner have to comprehensive a danger evaluation determined by available info.17Refer to "Examiner Growth of the BSA/AML Chance Assessment," website page 24, for advice. Assessing the Lender’s BSA/AML Chance Evaluation

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