The Financial Crime Risk Assessment is a crucial document required by Indonesian financial regulators to evaluate and document an organization's exposure to financial crime risks. It is typically conducted annually or when significant changes occur in the business environment, regulatory landscape, or organizational structure. The assessment helps organizations comply with OJK Regulation No. 12/POJK.01/2017 and related regulations while demonstrating their commitment to preventing financial crimes. This document encompasses detailed analysis of money laundering, terrorism financing, fraud, and corruption risks, evaluation of control effectiveness, and specific recommendations tailored to the Indonesian regulatory context. It serves as both a regulatory compliance tool and a strategic document for risk management decision-making.
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1. Executive Summary: High-level overview of key findings, major risk areas identified, and critical recommendations
2. Introduction and Scope: Purpose of the assessment, scope of review, and institutional context
3. Methodology: Detailed explanation of the risk assessment approach, data collection methods, and rating criteria used
4. Regulatory Framework: Overview of applicable laws, regulations, and compliance requirements in Indonesia
5. Inherent Risk Assessment: Analysis of inherent financial crime risks based on products, services, customers, channels, and geographic locations
6. Control Environment Assessment: Evaluation of existing controls, policies, procedures, and systems for financial crime prevention
7. Residual Risk Assessment: Assessment of remaining risks after considering control effectiveness
8. Gap Analysis: Identification of gaps between current state and regulatory requirements/best practices
9. Risk Rating and Conclusions: Overall risk ratings and key conclusions from the assessment
10. Recommendations: Detailed recommendations for addressing identified risks and gaps, including prioritization
1. Historical Context: Analysis of past incidents and previous risk assessments - include when there is relevant historical data
2. Technology Risk Assessment: Detailed analysis of technology and cybersecurity risks - include for institutions with significant digital operations
3. Third Party Risk Assessment: Evaluation of risks from third party relationships - include when the institution has significant vendor/partner relationships
4. Cross-Border Activities Assessment: Analysis of international operations risks - include for institutions with international operations
5. Implementation Roadmap: Detailed plan for implementing recommendations - include when specific action plans are required
6. Cost-Benefit Analysis: Analysis of costs vs benefits of recommended controls - include when significant investments are recommended
1. Appendix A - Risk Assessment Matrix: Detailed risk scoring matrix showing all risk factors and their ratings
2. Appendix B - Control Testing Results: Detailed results of control testing performed during the assessment
3. Appendix C - Interview List: List of key stakeholders interviewed and their roles
4. Appendix D - Document Review List: List of all documents reviewed during the assessment
5. Appendix E - Regulatory Requirements Mapping: Detailed mapping of regulatory requirements to current controls
6. Appendix F - Statistical Data: Relevant statistical data, transaction analysis, and trends
7. Appendix G - Action Item Register: Detailed list of recommended actions with ownership and timelines
8. Appendix H - Risk Rating Methodology: Detailed explanation of risk rating criteria and methodology
Relevant legal definitions
Clauses
Relevant Industries
Banking
Insurance
Securities and Investment
Payment Services
Money Services Business
Fintech
Asset Management
Credit Providers
Microfinance
Capital Markets
Relevant Teams
Risk Management
Compliance
Internal Audit
Legal
Operations
Financial Crime Prevention
Executive Leadership
Board of Directors
Regulatory Reporting
Anti-Money Laundering
Corporate Governance
Relevant Roles
Chief Risk Officer
Compliance Director
Head of Anti-Money Laundering
Risk Manager
Compliance Officer
Internal Audit Manager
Financial Crime Prevention Officer
Chief Executive Officer
Board Director
Regulatory Reporting Officer
Head of Legal
Chief Operating Officer
Risk Assessment Specialist
AML/CTF Analyst
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