AML Risk Assessment

The FFIEC manual recommends reassessing your financial institution’s BSA/AML risks every 12 to 18 months. While this process can be managed internally, obtaining an independent review offers valuable perspective and further demonstrates your institution’s commitment to compliance. Over the past 15 years, AML risk assessments have evolved—shifting from a largely qualitative approach to a more detailed, quantitative methodology. ARC Risk and Compliance provides the independent expertise needed to keep your assessments current and defensible.

Our risk assessment methodology has consistently demonstrated its advantages and has successfully withstood regulatory review year after year. We employ a scientific approach to quantitatively assess all risk factors, evaluate the effectiveness of your risk mitigation strategies, and determine the overall risk to your institution. By analyzing your bank’s data, we will provide a statistical analysis that clarifies the actual risk level compared to your perceptions.

“Our risk assessment methodology has consistently demonstrated its advantages and has successfully withstood regulatory review year after year.”

ARC’s Recommendations for an Effective Risk Assessment

Build the Foundation

  1. Review your BSA/OFAC Policies, Procedures, and Processes
  2. Document your Risk Assessment Methodology
  3. Ensure that you have current validations completed for all related systems

Erect the Structure

  1. Confirm your Customer Risk Rating (CRR) Methodology
  2. Ensure that you’re using consistent and reliable reporting data
  3. Include any secondary factors in your assessment, such as staff training, SARs filed, Subpoena/NSL Volume, Vendor Management, and CTRs, in your assessment

Prepare the Assessment

  1. Consider the regulatory environment, and account for that
  2. Try to consider future business expectations that can impact your overall risk
  3. Compile and document detailed workpapers

how can we help you?

Connect with us to learn more about ARC Risk and Compliance and our services.

We have utilized ARC Risk and Compliance for our last two independent verifications and validations of our Fiserv FCRM system. We are very happy with the team and work product, and would recommend them.

Alexander O. III
SVP/Chief Risk and Compliance Officer, mid-size commercial bank

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