The BSA/AML risk assessment is the document examiners open first, and the one most institutions treat as an annual formality. That mismatch explains a large share of program findings: the assessment says one thing, the controls do another, and nobody noticed because the assessment was written to be filed rather than to be used.
This is a working method for building one that actually drives the program.
What the Risk Assessment Is For
Its purpose is to identify the
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