The Conference of State Bank Supervisors (CSBS) recently released a new tool developed by the CSBS and state regulators to assist banks and non-depository financial institutions in managing Bank Secrecy Act/Anti-Money Laundering (BSA/AML) risk. According to the CSBS, the tool, known as the BSA/AML Self-Assessment Tool, is intended to improve the ability of institutions to identify, monitor and communicate BSA/AML risk.
Use of the tool is optional, and is intended to be a supplement to, not a replacement for, other aspects of an institution’s BSA/AML risk management program. The tool, which is provided in Microsoft Excel format, is designed to be flexible and is intended to be adapted to each institution’s circumstances and risk profile. The tool categorizes risks into three categories consistent with the BSA/AML Examination Manual, including: (1) products & services; (2) customers & entities; and (3) geographic locations. The tool also allows institutions to add risks identified during the identification process, and also allows institutions to omit inapplicable risks. The risk level will differ for each product and service, depending on the size and scope of the institution. The risk levels provided by the tool include: Low Risk: 1; Moderate Risk: 2; and High Risk: 3. Institutions using the tool are responsible for defining the levels of risk for each product and choosing the risk level most appropriate for the institution’s current operations. After each category is completed, the assessment tool will calculate the average for each category and determine a category’s inherent risk, and will also provide a combined inherent risk figure by taking a combined average of the average risk of each category.
The BSA/AML Self-Assessment Tool, as well as instructions and a narrated tutorial, can be viewed here: https://www.csbs.org/regulatory/resources/Pages/JobAids.aspx.