Report The RegSmartSM Risk Assessment yields a Composite Risk Rating for the institution as a whole and Categorical Risk Ratings for an institution's:
The purpose of this Risk Items Report is to:
It is important to understand that the Composite and Categorical Risk Ratings are compiled based on Residual Risk (where the institution has adjusted risk downward), not on Inherent Risk. RegSmartSM shows Inherent Risk below as a tool for the compliance professional and senior management to see where the institution's Inherent Risk is highest and where the institution has adjusted risk down with the proper application of mitigating controls.
This Report is a critical component for a Risk-Based approach to BSA/AML compliance-- allowing the compliance professional and senior management to apply human capital and technology to high risk areas. The Report also provides a critical summary of Inherent Risks and institution-assigned Residual Risk, which shows the internal or external compliance professional and auditor areas in which the institution believes mitigating controls reduce risk.
The accompanying Risk Items Report details each area (e.g., specific products, services, and customers) that represent higher BSA/AML Risk. It also shows areas that have high Inherent Risk to which your BSA professionals have applied mitigating controls and adjusted the risk profile accordingly. This will give you an idea of the areas in which your BSA/AML Program is expending (or should expend) human capital and technical resources in an effort to reduce risk.
Category | Category Risk | Item Affecting Risk Rating | Inherent Risk of Item (if applicable) |
Residual Risk of Item (if applicable) |
---|---|---|---|---|
Historical & Operational Data | Moderate | Asset Growth Rate Asset Size Material Change in CTR Filings Material Change in SAR Filings |
Moderate Moderate High |
N/A N/A N/A N/A |
Geographical | Low | HIDTA Concentration HIFCA Concentration |
Moderate Moderate |
Low Low |
Products & Services | Low | Demand Deposit Accounts | Moderate |
Low |
Customer Base | Moderate | Jewelry, Watch, Precious Stone, and Precious Metal Merchant Wholesalers | High |
Moderate |
Personnel & Training | Moderate | Teller Line Turnover Rate BSA Staff Turnover Rate |
Moderate Moderate |
N/A N/A |
BSA Compliance | Moderate | BSA Officer has other responsibilities that may impair BSA duties |
Moderate |
N/A |