BSA Risk Rating

By David Dickinson

I continue to bring you my notes from the ABA's Regulatory Compliance Conference. This session dealt with risk ratings. Not just the bank's BSA/OFAC risk rating, it also includes risk rating customers and employees of your institution.

Risk Assessment = analysis of current hazards AND future threats to your bank.

One person should not do the institution's BSA/OFAC risk assessment alone.

Don't forget to update your institution's BSA/OFAC risk assessment - at least annually.

Risk Rate employees? ID Theft, assisting in laundering money, embezzlement, etc.

The BSA Officer is in the best position to cover up these types of activities because of wide access to reports & systems information. Best position to steal.

Tellers - low pay, high temptation, high amount of opportunity.

Senior Officers who have access to cash and/or sensitive information.

Account Opening - risk rating accounts:

You must ask the difficult questions.

Treat all customers equally. Ask everyone the tough questions.

Risk Rate all customers.

Don't say "no risk" when rating customers.

Circular logic:

How do you know what is suspicious activity if you don't know the customer?

Then again, how do you assign a rating when you don't know the customer yet?

Hire competent help.

Blog

BSA Risk Rating