Consolidating ML/TF and other illicit financial activity risks for larger or more complex banking organizations may assist senior management and the board of directors in identifying, understanding, and appropriately mitigating risks within and across the banking organization. An initial AML/CFT risk assessment will measure the inherent risk. A customer risk rating tool or solution is normally utilized in … Applying Risk Findings 3. Anti-Money Laundering Questionnaire January 2015 1 globeSettle S.A. – Anti-Money Laundering Questionnaire I. When the risk assessment includes the inherent risk and measures the strength of controls, this results in a finding of the residual risk. x��}[s$7r��D��G�㰧p-��1'4��V{� ɒc�X���Ii�&^4�O�q� TuU�A��^I$Q�2q�+�zx����6�ӻ��������?��rw���~����ݏ��W������w? Identifying a vulnerability in one aspect of the banking organization may indicate vulnerabilities elsewhere. 1 0 obj SAMPLE BANK BSA/AML BANK RISK ASSESSMENT (April 2013) High Risk Scored as “3” Moderate Risk Scored as “2” Low Risk Scored as “1” Rating Score Comments 1 Large and growing customer base in … This questionnaire is designed to obtain information on the nature of operations, structure, activities and procedures so as to determine the specific money laundering, terrorist financing and proliferation financing risk … However that should K ome after the risk assessment.c The National Crime Agency (NCA) believes that money laundering costs the UK £24 billion a year1. stream Examiners should assess whether the bank has developed a BSA/AML risk assessment that identifies its ML/TF and other illicit financial activity risks. Understanding its risk profile enables the bank to better apply appropriate risk management processes to the BSA/AML compliance program to mitigate and manage risk and comply with BSA regulatory requirements. It is flexible and intended to be adapted to each institution’s circumstances and risk … This questionnaire is an important information-gathering exercise necessary for conducting an effective and informed assessment of Money Laundering/Terrorist Financing ML/TF risks in the Real Estate Industry. The assessment of risk factors is bank-specific, and a conclusion regarding the risk profile should be based on a consideration of all pertinent information. AML KYC BSA risk assessment and rating is performed during the client onboarding phase and also throughout the life of the customer. Regardless of the bank’s approach, sound practice would be to document the factors considered, including any weighting. Money laundering is the means by which criminals make the proceeds of crime appear legitimate. FINRA provides a template for small firms to assist them in fulfilling their responsibilities to establish the Anti-Money Laundering (AML) compliance program required by the Bank Secrecy Act (BSA) and its implementing regulations and FINRA … Examiners should also assess whether the bank has considered all products, services, customers, and geographic locations, and whether the bank analyzed the information relative to those risk categories. Further analysis by the second bank shows that 90 percent of its funds transfers are nonrecurring or are processed for noncustomers. The BSA/AML risk assessment should provide a comprehensive analysis of the bank’s ML/TF and other illicit financial activity risks. Improper identification and assessment of risk can have a cascading effect, creating deficiencies in multiple areas of internal controls and resulting in an overall weakened BSA/AML compliance program. using this questionnaire. Refer to Appendix I - Risk Assessment Link to the BSA/AML Compliance Program for a chart depicting the expected link of the BSA/AML risk assessment to the BSA/AML compliance program. Refer to the BSA/AML Compliance Program Structures section for more information. The purpose of this analysis is to assess ML/TF and other illicit financial activity risks in order to develop appropriate internal controls to mitigate overall risk. Further analysis by the first bank shows that approximately 90 percent of its funds transfers are recurring well-documented transactions for long-term customers. 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