In 2004 the FFIEC quietly and subtly shifted the BSA examination paradigm with the publication of the Bank Secrecy Act / Anti-Money Laundering Examination Manual (“the Manual”). The Manual introduced to examiners the concept of determining an institution’s money laundering, terrorist financing, and OFAC risks through a matrix of pertinent topics rated as Low, Medium, […]
The Foundations of the BSA/AML/CFT/OFAC Risk Assessment
