On September 10, 2019, the ACAMS New York Chapter hosted an panel discussion sponsored by Deloitte on Best Practices for Effective Risk Assessments.
The panel included (from left to right), moderator Jack Sonnenschein (Founder and Principal, Compliance Navigation LLC), Miriam Ratkovicova (Managing Director, Deloitte), Eric Kaplan (Head of BSA/AML Compliance, Mizuho Americas), and Rachel Sloan (Head of AML Programs, State Street Bank).
Approximately 180-200 professionals with varying levels of AML/FinCrime experience attended the event to hear the panel discuss how critical risk assessments are for overall enterprise risk management. The discussion began by addressing how risk assessments are a regulatory expectation in the US, in large part due to guidance provided in the BSA/AML FFIEC Exam Manual. Only recently have certain US regulators come closer to requiring that financial institutions conduct risk assessments (NYDFS Part 504 and OFAC’s Framework for Compliance Commitments), which aligns more closely with international regulatory guidance, such as EU AML Directives and the FATF’s Terrorist Financing Risk Assessment Guidance.
A recurring theme throughout the discussion was the need to adopt broader and more agile risk assessment methodologies across various financial crime disciplines. This may include real time factors such as significant events, law enforcement priorities, or internal trends from monitoring and investigations controls to identify and react faster to newly identified risks. Additionally, there may be opportunities to potentially consolidate and streamline the risk assessment process across the FinCrime disciplines (e.g., AML, Sanctions, AB&C) which have similar risk categories / risk factors. The use of advanced technology and analytics is critical for staying ahead and evolving with the need for more robust and effective risk assessments.