Sample Bank Bsa/aml Bank Risk Assessment

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SAMPLE BANK BSA/AML BANK RISK ASSESSMENT (April 2013)
High Risk
Moderate Risk
Low Risk
Rating
Comments
Scored as “3”
Scored as “2”
Scored as “1”
Score
Customer base increased more than
Large and growing customer base in
15% but no more than 30%
Stable, known customer base with
broad and diverse market area
1
compared to prior year due to
15% or less total deposit growth over
1
and/or customer base increased
branching, strategic growth plan,
prior year
more than 30% over prior year
merger or acquisition
2
More than 10 branches
Between 4 and 10 branches
Three or fewer branches
2
Many foreign private banking
Few foreign correspondent banking
accounts or foreign correspondent
accounts from low-risk areas and
Foreign private banking or
Measured by comparing foreign private
accounts, pouch activity or payable
minimal PTA and pouch activity or
3
correspondent account representing
1
banking or correspondent accounts to
through accounts (PTA) in high-risk
US dollar draft services representing
less than 5% of total deposit base
total deposit base
areas, representing more than 15%
more than 5% but 15% or less of
of total deposit base
total deposit base
Large number of international
Moderate level of international
Few international accounts and very
accounts with unexplained currency
accounts with unexplained activity of
low volume of international activity
Measured by comparing international
4
1
activity, representing more than 15%
more than 5% but less than or equal
representing less than 5% of total
accounts to total deposit base
of deposit base
to15% or deposit base
deposit base
Large number of noncustomer funds
transfer transactions and payable
upon proper identification (PUPID)
Moderate number of funds transfers
Limited number of funds transfers for
Measured by comparing funds transfers
transactions. Frequent fund transfers
with a few international transfers
customers, noncustomers, limited
(incoming and outgoing separately
5
from personal or business accounts
from personal or business accounts
1
third party transactions and no
calculated) to total funds transfers for the
to or from personal or business
in low-risk areas representing 15%
foreign fund transfers
past 12 months
accounts in high-risk areas,
or less of total wire transfer activity
representing more than 15% of total
wire transfers
Identified a large number of high-risk
Moderate number of high-risk
Measured by comparing high-risk
Few high-risk customers and
customers and businesses, with
customers and businesses
customer total relationships to total bank
businesses, representing less than
1
6
relationships totaling more than 30%
representing more than 10%, but not
customer relationships (calculating
10% of total deposits and loans
of total loans and deposits
more than 30%
deposits and loans separately)
Institution experiences a high
Institution experiences a moderate
Institution experiences a low volume
Measured by calculating percentage of
volume (> 30%) of large currency or
volume (> 15%, but < 30%) of large
(< 15%) of large currency or
transactions appearing on large dollar
7
2
structured transactions relative to
currency or structured transactions
structured transactions relative to
cash report compared to total cash activity
total cash activity
relative to total cash activity
total cash activity
for sample months.
Institution experiences a moderate
Institution experiences a moderate
Institution experiences a low volume
volume of reportable monetary
volume of reportable monetary
of reportable monetary instrument
Measured by calculating percentage of
instrument sales for cash (>$3,000
instrument sales for cash (>$3,000
sales for cash (>$3,000 but <
reportable monetary instrument sales for
8
1
but < $10,000) with total reportable
but < $10,000) with total reportable
$10,000) with total reportable
cash transactions during the past 12
transactions for the bank averaging
transactions for the bank averaging
transactions for the bank averaging
months
> $100,000 monthly
< $100,000 monthly but > $50,000
< $50,000 monthly
More than 15 Phase II Currency
Fewer than 15 but more than 5
9
Transaction Reporting (CTR)
Five or fewer Phase II Exemptions
1
Phase II Exemptions
Exemptions
Significant growing domestic and
Limited domestic private banking
international private banking or trust
services or trust and asset
Limited private banking services,
and asset management products or
management products or services
trust services and asset
Measured by calculating private banking,
services. Investment and trust
with investment discretion supportive
management services with
trust and asset management deposits
10
1
accounts are predominantly
of a strategy to grow trust business
combined deposits and/or loans of
and/or loans as a percentage of total
nondiscretionary representing more
representing more than 5% but no
<5% of total deposits and/or loans,
deposits and/or loans, as applicable.
than 15% of total deposits and/or
more than 15% of total deposits
as applicable
loans, as applicable
and/or loans, as applicable
More than 30% of branches located
More than 15% but less than 30% of
No more than 15% of branches
in an HIDTA/HIFCA* with large
branches located in an HIDTA/
located in HIDTA/HIFCA* with no
Measured by comparing branch locations
11
number of fund transfers or account
1
HIFCA* with some transfers or
fund transfers or account
to recent HIDTA and HIFCA area listings
relationships involving
accounts involving HIDTAs/HIFCAs
relationships involving HIDTA/HIFCA
HIDTAs/HIFCAs
Significant volume of transactions
Minimal high-risk transactions
Less than 5% of our customers send
This refers to wires, ACH, or other
conducted by more than 15% of our
conducted by more than 5% but less
transactions to or receive
12
1
transactions coming in from or being sent
customers within high-risk
than 15% of our customers within
transactions from transactions high-
to high risk areas
geographic locations
high-risk geographic locations
risk geographic locations
Wide array of e-banking products
and services including account
Limited e-banking products and
Less than 15% of our customers are
transfers, bill payment, remote
services with moderate customer
enrolled in e-banking products or
13
deposit capture, wire transfer
activity, more than 15% but less than
2
services, or institution web site is
origination with high customer
30% of total customers actively
completely non-transactional
activity, more than 30% of total
using e-banking
customers actively using e-banking
1

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