Objectives of the Presentation
- Basis for the Risk Assessment
- Understanding Customer Risk
- Understanding Products & Services Risk
- Understanding Geographical Risk
- Secondary Risks
- Institution's Trending
- Preparing the report
The risk assessment process should be considered a living process. According to the FFIEC Examination Manual: An effective BSA/AML compliance program controls risks associated with the bank's products, services, customers, entities, and geographic location; therefore, an effective risk assessment should be an ongoing process, not a one-time exercise. Management should update its risk assessment to identify changes in the bank's risk profile, as necessary (e.g., when new products and services are included, existing products and services change, higher-risk customers' open and close accounts, or the bank expands through mergers and acquisitions). Even in the absence of such changes, it is a sound practice for banks to periodically reassess their BSA/AML risks at least every 12 to 18 months.
ARC Risk and Compliance
William Schlameuss has over 20 years' experience in regulatory compliance, including BSA/AML/OFAC. He has worked with a wide range of US branches of major foreign banking organizations from all continents, both as chief compliance officer and compliance consultant. He has a prior background in IT as manager and implementer of core banking and payment systems, as well as compliance-related systems.
Mr. Schlameuss has extensive experience with State and Federal Banking regulators in examination preparation, assistance and response, including assistance in the remediation of written agreements for clients. As a project manager Mr. Schlameuss has led BSA/AML audits, BSA/OFAC Model Validations, remediation efforts of BSA audit issues , and BSA/OFAC look-backs for international banks, both self-imposed and directed by regulatory authorities. Model Validations included Prime, FCRM, Patriot Officer, Actimize, and eGIFTS.
He has conducted the Annual 3130 Supervisory Reviews for Broker-Dealers of the US branches of major FBOs. Mr. Schlameuss is also a member of the Association of International Bank Auditors and the International Bank Regulatory Compliance Committee.
- BSA/AML Officers, Compliance Officers, Chief Compliance Officers, Sanctions Officers, AML Analysts, Risk Officers, Chief Risk Officers, Legal Departments, Risk Managers and CEO/Presidents at Banks, Broker-Dealers, Money Services Businesses and other non-bank financial institutions.
- Chief Compliance Officers
- BSA Officers
- Risk Officers