Applying Risk Findings 3. General AML Policies, … ?z�_��|v�������7����|~|�混o��;�i��I��j�r��bs�y���w7���b����'l��#���r���J�kȆ4�Fm�߾���ln��}�� |C6j���/���lX�w���5|��!��|6m���4Hu��������'�[yr����/}��Ϧ���'j����P7��(���}K������\o�:����-�'����0n�������I3 Q¾�R��w[Ҝ. General AML Policies, … Examiners must develop an understanding of the bank’s ML/TF and other illicit financial activity risks to evaluate the bank’s BSA/AML compliance program. View the FFIEC Bank Secrecy Act/Anti-Money Laundering Manual Appendix I – Risk Assessment Link to the BSA/AML Compliance Program page under the Appendices section. For the purposes of the examination, whenever the bank has not developed a BSA/AML risk assessment, or the BSA/AML risk assessment is inadequate, examiners must develop a BSA/AML risk assessment for the bank based on available information. Generally, the first step in developing the risk assessment is to identify the bank’s risk categories. ACAMS Risk Assessment provides institutions worldwide an automated means of measuring, understanding and explaining their money laundering risks. 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 … Bank management designs the appropriate method or format and communicates the ML/TF and other illicit financial activity risks to all appropriate parties. <>>> When the bank has established an appropriate BSA/AML risk assessment process, and has followed existing policies, procedures, and processes, examiners should not criticize the bank for individual risk or process decisions unless those decisions impact the adequacy of some aspect of the bank’s BSA/AML compliance program or the bank’s compliance with BSA regulatory requirements. This section is designed to provide standards for examiners to assess the adequacy of the bank’s BSA/AML risk assessment process. Examiners should assess whether the bank has developed a BSA/AML risk assessment that identifies its ML/TF and other illicit financial activity risks. AML/CFT Risk Assessment. Anti-Money Laundering Questionnaire If you answer “no” to any question, additional information can be supplied at the end of the questionnaire. 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. Banks that choose to implement a consolidated or partially consolidated BSA/AML compliance program should assess risk within business lines and across activities and legal entities. Inherent risk is the risk that exists without any controls in place. stream Documenting the BSA/AML risk assessment in writing is a sound practice … 4 0 obj 3 0 obj AML Monitoring Questionnaire Important Note Below are the contents of the questionnaire for your easy reference. Documenting the BSA/AML risk assessment in writing is a sound practice to effectively communicate ML/TF and other illicit financial activity risks to appropriate bank personnel. You must undertake a ML/TF risk assessment so you can develop an appropriate written AML/CTF program, review it regularly and update it when there are changes to your business or organisation. Please note that the questionnaire is required to be completed and submitted on-line on or before 13 January 2019 and hard copy submission will not be accepted. The bank structures its BSA/AML compliance program to address its risk profile, based on the bank’s assessment of risks, as well as to comply with BSA regulatory requirements. Anti-money laundering firm-wide risk assessment Under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), it is a legal requirement for every accountancy firm to have a documented firm-wide risk assessment. Specifically, the bank should develop appropriate policies, procedures, and processes to monitor and control its ML/TF and other illicit financial activity risks. However that should K ome after the risk assessment.c For example, the bank’s monitoring system to identify, research, and report suspicious activity should be risk-based to incorporate any necessary additional screening for higher-risk products, services, customers, and geographic locations as identified by the bank’s BSA/AML risk assessment. Developing a AML/CFT risk methodology 2. There are four main elements you need to think about in working out money laundering or terrorism financing risk. When the risk assessment includes the inherent risk and measures the strength of controls, this results in a finding of the residual risk. Audit results of the Risk Assessment … Money laundering also includes the fundin… For example, it may be useful to quantify risk by assessing the number and dollar amount of domestic and international funds transfers, the nature of private banking customers or foreign correspondent accounts, the existence of payable through accounts, and the domestic and international geographic locations where the bank conducts or transacts business. <> While not a specific legal requirement, a well-developed BSA/AML risk assessment assists the bank in identifying ML/TF and other illicit financial activity risks and in developing appropriate internal controls (i.e., policies, procedures, and processes). Residual Risk. AML KYC BSA risk assessment and rating is performed during the client onboarding phase and also throughout the life of the customer. Further analysis by the second bank shows that 90 percent of its funds transfers are nonrecurring or are processed for noncustomers. Responses should be provided in the designated spaces in the questionnaire. Any single indicator does not necessarily determine the existence of lower or higher risk. The agency should also consider its response to fraud risk … D. General Anti-Money Laundering Policies, Practices & Procedures If you answer “no” to any question, additional information can be supplied at the end of the questionnaire. A report must be lodged with your AML/CFT Supervisor each year in a specified format. There are no required risk categories, and the number and detail of these categories vary based on the bank’s size or complexity, and organizational structure. Objective: Review the bank’s BSA/AML risk assessment process, and determine whether the bank has adequately identified the ML/TF and other illicit financial activity risks within its banking operations. AML/CFT programme. <> CSBS and a group of state BSA/AML subject-matter experts developed the BSA/AML Self-Assessment Tool to be used at the discretion of a financial institution to help in the BSA/AML risk assessment process. Note that you must also have your firm’s AML policy approved by senior management (Regulation 19). This document sets out information on money laundering and terrorist financing risk that we consider relevant to those we supervise. Money laundering, terrorist financing, or other illicit financial activities can occur through any number of different methods or channels. However, there is no requirement to update the BSA/AML risk assessment on a continuous or specified periodic basis. The information requested by this questionnaire … <>/ExtGState<>/Font<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 595.32 843] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> Through preventing money laundering, we can take away criminals' incentives to traffic weapons, trade drugs or engage in human trafficking. When evaluating the BSA/AML risk assessment, examiners should focus on whether the bank has effective processes resulting in a well-developed BSA/AML risk assessment. The AML/CFT risk assessment guideline was updated in 2018 and is designed to help reporting entities conduct a risk assessment, as required under section 58 of the Anti-Money Laundering and Countering … Additionally, the appropriate level and sophistication of the analysis varies by bank. Various methods and formats may be used to complete the BSA/AML risk assessment; therefore, there is no expectation for a particular method or format. While the risk assessment is the responsibility of the FI as a whole, the money laundering risk assessment will usually be designed and carried out by the competent AML Unit, applying specialist … This is primarily achieved by reviewing the bank’s BSA/AML risk assessment during the scoping and planning process. 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. The theory supporting risk assessment tools and templates is based on the concept that a client’s risk AML profile can be measured by applying data-driven and risk-based calculations on risk categories … While these percentages appear to be the same, the risks may be different. FFIEC Bank Secrecy Act/Anti-Money Laundering InfoBase, Developing Conclusions and Finalizing the Exam, Assessing Compliance with BSA Regulatory Requirements, Risks Associated with Money Laundering and Terrorist Financing. The bank’s BSA/AML risk assessment process should address the varying degrees of risk associated with its products, services, customers, and geographic locations, as appropriate. 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 … 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. The BSA/AML risk assessment should provide a comprehensive analysis of the bank’s ML/TF and other illicit financial activity risks. The following example illustrates the value of the two-step risk assessment process. The questionnaire is an important tool for the Institute to gather information on the nature and extent of professional services provided by its constituents for the purposes of assessing the ML / TF risks of the accounting profession. using this questionnaire. 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 … endobj The assessment should consider incentives and pressures, opportunities to commit inappropriate acts and, how management and other personnel might engage in or justify inappropriate actions. It is flexible and intended to be adapted to each institution’s circumstances and risk … 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. Identifying a vulnerability in one aspect of the banking organization may indicate vulnerabilities elsewhere. %PDF-1.5 2 0 obj 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? The information collected by two banks in the first step reflects that each sends 100 international funds transfers per day. Generally, the second step in developing the BSA/AML risk assessment entails an analysis of the information obtained when identifying specific risk categories. Examiners may also refer to Appendix J - Quantity of Risk Matrix when completing this evaluation. For example, the number of funds transfers may be one factor the bank considers when assessing risk. 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. An initial AML/CFT risk assessment will measure the inherent risk. endobj Further analysis by the first bank shows that approximately 90 percent of its funds transfers are recurring well-documented transactions for long-term customers. Examiners should have a general understanding of the bank’s ML/TF and other illicit financial activity risks from the examination scoping and planning process. Anti-Money Laundering Questionnaire January 2015 1 globeSettle S.A. – Anti-Money Laundering Questionnaire I. However, to identify and weigh the risks, the bank’s risk assessment process may need to consider other factors associated with those funds transfers, such as whether they are international or domestic, the dollar amounts involved, and the nature of the customer relationships. A detailed analysis is important, because the risks associated with the bank’s activities vary. To assist Firms to adopt appropriate practices to mitigate the risk of money laundering, terrorist financing and fraud, the Regulatory Authority have developed this AML/CFT Self Assessment which … To assure that BSA/AML compliance programs are reasonably designed to meet BSA regulatory requirements, banks structure their compliance programs to be risk-based. Money laundering is the means by which criminals make the proceeds of crime appear legitimate. The BSA/AML risk assessment process also enables the bank to better identify and mitigate any gaps in controls. Generally, risk assessments are updated (in whole or in part) to include changes in the bank’s products, services, customers, and geographic locations and to remain an accurate reflection of the bank’s ML/TF and other illicit financial activity risks. The Risk Assessment Quantification * Source of Funds Risk … Regardless of the bank’s approach, sound practice would be to document the factors considered, including any weighting. The BSA/AML risk assessment should be provided to all business lines across the bank, the board of directors, management, and appropriate staff. 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. I. For example, the bank may need to update its BSA/AML risk assessment when new products, services, and customer types are introduced or the bank expands through mergers and acquisitions. 1 0 obj An examiner-developed BSA/AML risk assessment generally is not as comprehensive as one developed by the bank. Based on the various considerations above which are intended to prompt considerations of areas that may be considered to be of a higher risk from a money laundering perspective, each firm is required to conclude on an overall money laundering risk assessment … The development of the BSA/AML risk assessment generally involves the identification of specific risk categories (e.g., products, services, customers, and geographic locations) unique to the bank, and an analysis of the information identified to better assess the risks within these specific risk categories. Refer to the Customer Identification Program, Customer Due Diligence, and Appendix J – Quantity of Risk Matrix sections for more information. The identification of risk categories is bank-specific, and a conclusion regarding the risk categories should be based on a consideration of all pertinent information. 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. The questionnaire … The National Crime Agency (NCA) believes that money laundering costs the UK £24 billion a year1. Examiners should not take any single indicator as determinative of the existence of a lower- or higher-risk profile for the bank. GENERAL INFORMATION ABOUT THE APPLICANT 1) Regulatory status of the applicant The applicant is regulated as a: ... - A Risk … This step may involve evaluating transaction data pertaining to the bank’s activities relative to products, services, customers, and geographic locations. A spectrum of risks may be identifiable even within the same risk category. This example illustrates that information collected for purposes of the bank’s customer identification program and developing the customer due diligence customer risk profile is important when conducting a detailed analysis. The bank may determine that some factors should be weighted more heavily than others. %���� I. The subsections within Risks Associated with Money Laundering and Terrorist Financing provide information and discussions on certain products, services, customers, and geographic locations that may present unique challenges and exposures, which banks may need to address through specific policies, procedures, and processes. 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 BSA/AML risk assessment should provide a comprehensive analysis of the bank’s ML/TF and other illicit financial activity risks. Refer to the BSA/AML Compliance Program Structures section for more information. Inherent Risk. Anti-Money Laundering and Due Diligence Questionnaire (FILLED IN FOR OUR CORRESPONDENT BANKS/ EXCHANGE COMPANIES DEALING WITH ALLIED BANK LIMITED) Section I – General Information … A customer risk rating tool or solution is normally utilized in … This information should be evaluated using the two-step approach detailed in the BSA/AML Risk Assessment Process subsection above. endobj THE NATURE OF AML/CFT RISK ASSESSMENTS (Business & Customer) 1. egulator on demand a copy of your risk assessment, and all steps taken to carry it out (Regulation 18(6)).r 2.eep your records of such meetings or consultations. Independent testing (audit) should review the bank’s BSA/AML risk assessment, including how it is used to develop the BSA/AML compliance program. The Annual Report contains questions about the following: Organisational structure. 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