Blog

Blog

FinCEN’s New CDD Rule & Significant and Unexplained Changes

April 16 2018 by Dave Gowan

FinCEN’s Final Rule regarding Customer Due Diligence (CDD) Requirements for Financial Institutions[1] (The New CDD Rule on Beneficial Ownership) is wrapped...

Read more

High Risk Customers: Where to Begin

March 14 2018 by Dave Gowan

As a state or federally regulated financial institution, it’s important to have a grasp of what constitutes a high-risk customer as it pertains to BSA and...

Read more

A Risk Model and Model Risk are not the same…

February 17 2017 by Dave Gowan

Model risk is defined by the Office of the Comptroller of the Currency (OCC) as “the potential for adverse consequences from decisions based on incorrect or...

Read more

What is the Purpose of a Risk Assessment?

February 16 2017 by Dave Gowan

A risk assessment allows the financial institution to look at itself with a sense of introspection; to “identify the specific products, services, customers,...

Read more

An Overview of How Risk Assessments are Critical to Development of a Risk Model

February 14 2017 by Dave Gowan

The development of a BSA/AML risk assessment for any financial institution is a necessary step in the development of a financial institution’s overall risk...

Read more

The Evolution of a Risk Assessment to a Risk Model

February 13 2017 by Dave Gowan

A risk mitigation strategy as it pertains to specific regulatory compliance functions within a financial institution becomes part of the specific risk model. For an...

Read more