Tellers and Customer Service Representatives play a crucial role when it comes to developing a customer’s risk profile. They are on the frontline working directly with the customer which gives them the ability to ask questions. Knowing what to ask and when are vital to your BSA/AML program.
The idea behind having a BSA Risk Assessment is to break down your bank’s BSA/AML risks into smaller, more manageable parts. There is no specific methodology which means that each bank’s risk assessment can, and likely will, look different. No two banks are the same. The BSA Officer and your BSA Team play a crucial role in developing and updating your risk assessment.
Crypto/Virtual currency is growing by leaps and bounds and is becoming more prevalent and mainstream. If you haven’t seen it pop up yet at your institution, it’s probably only a matter of time. If you haven’t conducted a risk assessment from a BSA/AML perspective, it’s something you are going to want to do. Management needs to be aware of the potential risks as well as how to mitigate those risks as you move forward.
In our December 2021 Monthly Connection, we discussed the FFIEC’s December 1, 2021, updates to the BSA/AML Examination Manual. While the updates weren’t major, they did reinforce the idea that certain types of customers (or categories of customers) are not automatically high risk. Any designation as such should be based on that specific customer relationship. This, in turn, shines a light on the need for adequate customer due diligence (CDD) procedures both upfront and that are ongoing throughout the relationship.