Risk Assessment — BSA/AML & OFAC for a Latin American Bank

Foodman CPAs & Advisors was hired by a large Latin America based bank to perform a Risk Assessment for BSA/AML and OFAC ("A Framework for OFAC Compliance Commitments"), intended to identify the money laundering, terrorist financing and sanctions-related risks that the Bank faced and the internal controls they currently have in place to protect the Bank.

Foodman conducted an assessment of the BSA/AML risks posed by the Bank's customer base, products, services, transactions and geographic locations. The risk assessment reports evaluated inherent risks associated with the Bank's products, services, customers, entities and geographic locations. It also identified other qualitative factors and the strength of existing mitigating controls for describing the residual risk that remains after the controls are considered.

The risk assessment reports had the following objectives:

• Providing a depiction of the Bank's BSA/AML & OFAC compliance risk exposure for informing decision‑making by the Board, senior management and the compliance team.
• Identifying BSA/AML & OFAC compliance risks requiring action by Management and Compliance Staff.
• Enhancing the Quality of Risk Management.