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Risk Assessments Risk Appetite

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Slide 1 - Risk Assessments/Risk Appetite Judith Gruenbaum 1
Slide 2 - 2
Slide 4 - 4 Risk exposure to the chance of injury or loss a hazard or dangerous chance Assessment the act of estimating or judging the value or character; evaluation Appetite a desire or liking for something; fondness; taste Definitions
Slide 5 - 5 Assesses the financial institution’s risk profile (BSA/AML, Privacy, Fair Lending, LOB) Enables the financial institution to apply the appropriate risk management processes to the applicable Compliance program to mitigate risk Allows management to better identify and mitigate gaps in the organization’s compliance controls Provides a comprehensive analysis of the applicable risk in a concise and organized presentation Benefits of an Effective Risk Assessment
Slide 6 - 6 Executive Compliance Management Executive Business Management Risk Committees or similar forums Auditors Compliance Testing Personnel Supervisors/Regulators Primary Audiences
Slide 7 - 7 Dynamic and proactive Consolidated understanding of risk exposure Coordinated risk management Assess evolving risks when new business lines or activities are added or when existing activities and processes change or when regulatory requirements change Deficiencies in one area may indicate a concern in another area – be sure to look across the organization Elements of an Effective Enterprise-wide Risk Management Program
Slide 8 - 8
Slide 9 - Identify Applicable Regulatory Requirements Establish change control processes Measure risk against consistent compliance risk rating definitions. Updates to risk ratings as warranted by changes in risk environment (e.g., significant business changes, regulatory focus, audit/exam/compliance testing results, etc.) Establish an appropriate control environment based on identified risks Link Compliance Testing and Audit plans to identified risks 9 Compliance Risk Assessment Framework
Slide 10 - 10 Products Clients Geography (Domestic or International Exposure) Forward Looking – changes in business strategy; new products, expanding to new markets, or exiting products/markets Assess and Quantify Inherent Risk
Slide 11 - 11 Governance Management Oversight/Resources Customer/Client Identification and Due Diligence Management Information Systems Regulatory Reporting (e.g. CTRs, SARs) Training Testing/Audit Coverage/Examination Findings Quantify Compliance Controls
Slide 12 - 12 Profile of the business Key Inherent Risk Factors Primary factors that contributed to the risk levels assigned Key Mitigation Factors/Controls Factors that contributed to the strength or weakness of controls Residual Risk Direction of Risk Trend Where is your risk headed in the next 12-18 months? Increasing? Decreasing? Stable? Why? Summarize the Results
Slide 13 - 13 Money Laundering Risk Assessment and MitigationComunicate the Results Communicate the Results Communicate the Results
Slide 14 - 14 DO If you want it to count, then write it down! Create a workable template and framework including written procedures and guidance Invest in the technology Use the risk assessments Drive/Focus Resources Training Monitoring Independent testing or Audit Scoping/Planning Validating the Assessment and Controls DON’T Believe anyone that says there is one right way to do it Think of this as a once a year compliance exercise Put it on the shelf and forget about it Forget to document the analysis portion Do’s and Don’ts
Slide 15 - 15