On demand · 40 minutes · Recorded October 8, 2026

Risk Assessment vs. Transaction Monitoring

Complementary, not interchangeable. A bank Chief Risk Officer and an AML consultant on why each has to test the other, and what examiners look for first.

Chapters

  1. What an entity-wide risk assessment is for
  2. Where to point the flashlight
  3. Using monitoring results to test the assessment
  4. The proposed AML/CFT program rule
  5. What examiners look for first
  6. Where programs break down
  7. Case study: an OCC consent order
  8. Poll: how often do you retune?
  9. Poll: where the manual hours go
  10. Closing thoughts
The distinction

One tells you where to look. The other tells you what you found.

Risk assessment

Where should we point the flashlight?

Strategic and bank-wide. Rates inherent and residual risk across customers, products and services, delivery channels and geography, and tells the board where resources belong.

Transaction monitoring

What did the light find?

Tactical and continuous. Applies rules and thresholds to activity and produces alerts, investigations and SARs.

The assessment is a blueprint, and it has to be living

It comes first because a risk-based program cannot be designed until you know where the risk lies. It cannot sit still, because monitoring results have to flow back into it.

Cody J. Smith

The feedback loop is the test

If your assessment puts your risk in international activity and every SAR you file is domestic fraud, the risk is misstated, monitoring is miscalibrated, or both.

Cody J. Smith

Can you explain the rating?

Examiners start with logic, then alignment to what the bank actually does, then data integrity. If management cannot explain a rating, the rating is not helping.

Andrea Valentin

Every threshold needs a story

If the monitoring team cannot explain why a threshold exists, it is not good enough. A rule producing zero alerts is a question, not a clean bill of health.

Andrea Valentin
From the live audience

Three in four said alert work is their heaviest manual load.

Which area of your BSA/AML program demands the most manual effort?

Clearing and investigating alerts75%
Maintaining the annual risk assessment13%
Managing exams and lookbacks0%

How often do you tune monitoring rules based on changes in your risk assessment?

Dynamically, as risk shifts60%
Annually25%
Rarely or never13%
Only after regulator or auditor findings6%

Live polls of webinar attendees, October 8, 2026. Remaining responses to the first question named CDD/EDD for high-risk customers.

The panel

Andrea Valentin

CFE · CAMS · CFCS

Chief Risk Officer, Maxwell State Bank. Speaker and advisor with the Financial Fraud Consortium. Views her own.

Cody J. Smith

CPAML

Managing Director, CSMB International, and Chief Product Officer, RiskRator.

Jose Lamas

Moderator

Co-Founder and Chief Revenue Officer, RiskRator.

See what your own transaction data says about your institution’s risk.

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