Answer:
Answer by Ken Golliher: A search of your examiner's brain might be helpful, but my guess is you would come up empty there as well. It's a phrase originating with an individual, not the examination handbook or examination procedures.
The process described, "analysis of data obtained during the identification stage in order to assess risk" sounds like a merger of CIP and due diligence. It might be applied at account inception to mitigate risk, but it would not be part of the risk assessment itself.
Whenever you get an instruction from an examiner you do not understand ask him or her what it is they are talking about. Sometimes they know...
Answer:
Answer by Randy Carey: I agree with Ken, when in doubt, ask them what they are talking about. It may have to do with your risk rating process. If you say your wire transfer area is low risk, but you have no data to support that assessment, i.e., total domestic and international transfers, list of countries where wires are typically sent, etc., they may be indicating that your risk assessment is unsubstantiated by accompanying data.
First published on BankersOnline.com 10/3/11
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