Our bank has 44 branches; however, at the end of April, we are closing 11 of those branches. As a result, our risk should go down slightly as a large amount of our branches are located in a HIDTA area. I normally update our BSA/AML Risk Assessment every January, but I am wondering if I should perform an update at the end of April to reflect our branch closures. Your thoughts are appreciated.

I update my BSA/AML/OFAC Risk Assessment annually or when a material change occurs. I'd say closing 25% of your branch network qualifies as a material change.

IMHO, the Risk Assessment should be a living document that is changed whenever appropriate, keeping in mind that you should still review it annually in case something changed that you weren't told about.

Agreed. I would update for such a major change.