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The existence of BSA/AML risk inside the aggregate hazard profile shouldn't be criticized so long as the financial institution’s BSA/AML compliance software sufficiently identifies, steps, screens, and controls this danger as Element of a deliberate threat approach. When the risks are usually not correctly managed, examiners have to communicate to management along with the board of administrators the need to mitigate BSA/AML chance. Examiners really should doc deficiencies as directed within the Main examination procedures, "Building Conclusions and Finalizing the Examination," website page 43.
To prevent having an outdated knowledge of the BSA/AML threat exposures, the banking organization should really frequently reassess its BSA/AML threats and talk to business units, features, and legal entities. The identification of a BSA/AML chance or deficiency in one region of business may possibly show problems in other places while in the organization, which administration must determine and control. Seek advice from the expanded overview segment, "BSA/AML Compliance System Buildings," web site one hundred fifty five, For added steering.
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