Answer:
It depends on what is reflected in your BSA policy and procedures. If your policy states they are subject to periodic monitoring, then that would be the examiner’s expectation. Even if your policy is silent, your examiner may facilitate a discussion to assess how the moderate risk rating is determined by the ASM system and why your institution made the determination that they are not at risk for money laundering, fraud or terrorist financing.
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Learn more about Robin Guthridge’s, Mastering High Risk Monitoring webinar.
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