Overview federal financial institutions examination council. The may 11, 2016, final rule on customer due diligence cdd requirements created an entirely new section, 31 cfr 1010. The strength of the language in the exam manual makes it easy to deduce that a comprehensive, risk based assessment will be the focal point of a banks bsa examination. These examination procedures are for banking lcblicensed marijuana related credit unions businesses. Ffiec bsaaml appendices appendix j quantity of risk. Bank secrecy actantimoney laundering bsa aml office of foreign assets control ofac. Csbs and a group of state bsa aml subjectmatter experts developed the bsaaml self assessment tool to be used at the discretion of a financial institution to help in the bsa aml risk assessment process. The revised federal financial institutions examinations councils ffiec bsa aml examination manual states that a financial institutions risk assessment. The msb bsa aml self assessment tool is not a substitute for a risk assessment institutions that choose to use this self assessment tool should use it in addition to the fincen bsa aml examination manual. Evaluating the bsa aml risk assessment should be part of scoping and planning the examination, and the inclusion of a section on risk assessment in the manual does not mean the two processes are separate. Operations of foreign banking organizations 2003 rating system for u. Ffiec it examination handbook infobase risk assessment. The msb bsa aml self assessment tool is not a requirement msbs should not feel obligated to performing the self assessment.
Banks and examiners may use the following matrix to formulate summary conclusions. Rmlos risk categories and provide a detailed analysis to assess the level of risk. It is flexible and intended to be adapted to each institutions circumstances and risk profile. In essence, the bsa aml risk assessment is viewed as a roadmap for understanding the banks risk profile and thereby providing the foundation for.
Regulator panel 04152018final west coast antimoney. Does anyone have a template for an ofac risk assessment. The template provides text examples, instructions, relevant rules and websites and other resources that are useful for. Joint statement on risk focused bsa aml supervision opens new window sharing bsa resources opens. Based on its risk assessment, a bank may require identifying information in addition to the items above for certain customers or product lines. The graphic below from the ffiec bsaaml examination manual4. Current enforcement trends will be highlighted and new and emerging areas of risk will be discussed. Bank secrecy act bsaantimoney laundering aml examination. Bsaaml risk assessment for money services businesses msbs.
In fact, the ffiec bsa aml examination manual emphasizes that examiners evaluate the financial institutions risk assessment as part of the planning and scoping phase of the examination. Several resources are available to institutions seeking to ensure compliance in this area. Bsa summary and ofac risk assessment considerations of nov 2009 pub aug 2010. In this video, affirmxs senior analyst, coppelia padgett, provides an. To view specific sections of the manual, select within the left column. The following information gathered was utilized as a guide to determine what information should be included in the new risk assessment. Finra provides a template for small firms to assist them in fulfilling their responsibilities to establish the antimoney laundering aml compliance program required by the bank secrecy act bsa and its implementing regulations and finra rule 3310. Bank secrecy actantimoney laundering examination manual for. This bsa aml self assessment tool assessment tool is voluntary and may be used at your institutions discretion. However, the answers are not meant to be comprehensive, apply to all factual situations, or to replacesupersede the bsa regulations. Sample msb examination manual work program december 2008 pdf only.
Appendix i risk assessment link to the bsaaml compliance program. Assess the bsa aml risk profile of the bank and evaluate the adequacy of the banks bsa aml risk assessment process. National exam risk alert mastersub accounts september 29, 2011. Therefore, the content in the pdf version takes precedence over the content in the audio version. Revised ffiec bank secrecy actantimoney laundering examination manual and infobase fil732007. Note 1 the mp3 files may not be complete copies of the pdf files due to the exclusion of charts and tables that do not convert well to audio presentations. This booklet addresses compliance banks with the secure and fair enforcement for mortgage licensing safe act of 2008, which mandates a nationwide licensing and registration system for residential mortgage loan originators. In a recent exam by the ncua we were told that our bsa risk assessment is outdated for our current size. Bank secrecy actantimoney laundering examination manual for money services businesses examination procedures 29 preplanning the bsa examination 29 preplan procedures 29 risk assessment 32 developing a risk based examination plan 32 transaction testing plan 33 msb registration requirements overview 34 msb agent list 35 examination procedures 37 msb.
The bsa aml self assessment tool is not a substitute for a risk assessment institutions that choose to use this self assessment tool should use it in addition to the ffiec bsa aml examination manual1 and corresponding laws and regulations, not as a replacement. Also on the panel was john wagner, occs new director for bsa. On page 57 of the bsa aml examination manual published in february 2015, the title of the section is enhanced due diligence for higher risk customer. Bsaaml examination manual section list and download options. The online link under view allows you to see the selected section online or by selecting pdf under download you can print or save the selected section. Bsa aml examination manual was revised in april 2010, ffiec replaced the phrase high risk customer with higher risk customer throughout the manual to avoid this type of confusion. The following lists provide the steps for creating a risk assessment and the reasons each category presents. The cip must contain risk based procedures for verifying the identity of the customer within a reasonable period of time after the account is opened. Each institution can utilize these tools along with other resources, such as the new ffiec manual, to design your own customized program.
Risk assessment for financial institutions carr, riggs. Ffiec aml examination manual february 2015, available at. Ffiec bsaaml compliance program bsaaml risk assessment. Bank secrecy actantimoney laundering examination manual. How to perform a financial institution risk assessment. It operations comprise the framework of service and product delivery to internal and external customers and are intrinsic to much of the risk management undertaken by the institution.
The publications below provide guidance to officials examining money services businesses msbs for compliance with the requirements of the bank secrecy act bsa. Its been nearly half a decade since the ffiec and fincen have released a new update of the bsa aml examination manual. The management booklet of the ffiec1 it examination handbook and the ffiec bank secrecy actantimoney laundering bsa aml examination manual provide highlevel descriptions of risk management processes that include planning, risk identification and assessment, controls, and. According to ncua, credit unions must use a risk based approach when developing their programs. Bank secrecy act antimoney laundering examination manual for money services businesses december 2008 pdf only. Bsa summary and ofac risk assessment considerations of nov. Assessing the bsa aml compliance program and address areas such as scoping and planning and the bsa aml risk assessment and compliance program regulatory requirements and related topics which include the customer identification program, customer due diligence, suspicious activity reporting, funds transfers recordkeeping. Prior to using this matrix, they should complete the identification and quantification steps detailed in the bsa aml risk assessment overview section at page 18 of this manual. Get answers the latest discussions in the cbanc community.
He stressed the four elements of an effective bsa program. Determine whether the bank has included all risk areas, including any new products, services, or customers, entities, and geographic locations. Bank secrecy act antimoney laundering examination manual. Operations 2002 examination planning and the assessment of the u. The bank secrecy act bsa, initially adopted in 1970, establishes. This is one more risk assessment tool being distributed to national banks as part of the occs exam process.
For more information on bsa aml risk assessments for small msbs, please see the references and resources provided with this article. Riskbased approach guidance for the banking sector fatf. Recent changes to the bsa examination manual will be noted, together with some practical ways you can raise bsa awareness among bank management and staff. The online link under view allows you to see the selected section online or by selecting pdf under download you.
For more information about bsa compliance, see the ffiecs bsa antimoney laundering examination manual. December 31, 2008, and the next renewal must be filed by december 31, 2010. Bsaaml selfassessment tool overview and instructions. Bsa risk assessment compliance risk bsaaml risk assessment. Manual provides guidance on risk assessments, with examples. Bank secrecy act bsa and related rules and regulations. Bank secrecy act antimoney laundering examination manual federal financial institutions examination council board of governors of the federal reserve system, federal deposit insurance corporation, national credit union administration, office of the comptroller of the currency, office of thrift supervision, and state liaison committee 2010.
Examination resources examination manuals and guidance. Ffiec bsa aml examination manual 3 05052018 examiners should primarily focus on whether the bank has effective processes to develop customer risk profiles as part of the overall cdd program. Revised bank secrecy actantimoney laundering examination manual fil602014. Acams risk assessment provides an automated means of measuring, understanding and explaining an institutions money laundering risks. Confirm that credit union conducts a risk assessment of wire transfers and acts in accordance with the findings of the assessment. This rescission applies to the transmitting document only and. Bsa aml examination manual section list and download options. One of the provisions is that covered financial institutions are required to establish and maintain written procedures that are reasonably designed to identify and verify beneficial owners of legal entity customers and. Core examination procedures for assessing the bsaaml compliance program. Revisions to the ffiec bsaaml manual to include the new. An introduction to the ffiec bsa aml examination manual and related concepts.
Covered institutions should focus particularly on the manual s appendix k. For these reasons, management should not limit the risk assessment process to risks associated with specific platform s, their operating system s, resident. Branches and agencies of foreign banking organizations 2010 risk focused approach to pre examination planning 2020 loan sampling. Document library a searchable, sortable archive of the documents uploaded to cbanc. Like any other business line at a regulated examiners should assess the credit union, effectiveness of program governance, the risk management framework, operational procedures, and.
See also bcbs 2010b, and bcbs 2014a consultative document on. The sections of the ffiec bsaaml examination manual that have been added or significantly. The risk assessment should provide a comprehensive analysis of the. The bank secrecy act antimoney laundering examination manual. Related to these is a form made available by the occ. Guidance to examiners on examination scoping and planning, assessing the bsa risk assessment and compliance program, and developing conclusions and finalizing the exam. For example, if the examiner determines that a money transmitter may.