Risk-based Assessment. The PI team will meet to evaluate, and assess the last performance year’s focused reviews and determine if there are any outstanding risk that were identified from the focused reviews or other program or project observations. Using a risk-based approach the PI team will identify all the preconstruction and construction focused risk reviews for the next performance year.
Risk-based Assessment. During the FHWA Division’s (MoDIV) annual risk assessment process, TEs and Program Specialists will identify potential risk areas that could be addressed with PoDI activities on projects where those higher risk items are likely to occur. This includes evaluating results from last year’s risk activities, such as findings from program reviews, CAP reviews, focused reviews, and other project approval actions (per the Stewardship and Oversight Agreement) to determine if any risks should be carried over to the next year. Using a risk-based approach, the FHWA Division will identify all the program, preconstruction and construction PoDI focused reviews or other activities for the next federal fiscal year.
Risk-based Assessment. During the Division’s annual risk assessment process, TEs and Program Specialists will identify potential risk areas that could be addressed with PoDI activities on projects where those higher risk items are likely to occur. This includes evaluating results from last year’s risk activities, such as findings from program reviews, CAP reviews, focused reviews, and other project approval actions (per the Stewardship and Oversight Agreement) to determine if any risks should be carried over to the next year. Using a risk-based approach the Division will identify all the program, preconstruction and construction PoDI focused reviews or other activities for the next fiscal year.
Risk-based Assessment. The Division will enter all Major Projects and all other pre-screened projects that have the potential to be a PoCI into the FHWA SharePoint-based Resource Deployment Tool. This tool will be used to conduct a risk-based assessment to identify areas of elevated risk for each project, identify the level of Division office capacity to manage the risk, and determine if the project is recommended by the Division Office for selection as a final PoCI. The Resource Deployment Tool considers the project risks in the areas of: 1) complexity, 2) Cost, 3) Schedule, 4) Urgency,
Risk-based Assessment. Most jurisdictions impose a requirement that the custodian assign money laundering risk rating to each customer. This exercise identifies customers that may poses a higher risk and the custodian conducts enhanced due diligence and imposes more extensive monitoring and more frequent risk assessment on these accounts. Furthermore, many of the anti-money laundering laws applicable to the global custodians, including those in the United States, allow for custodian to take a risk-based approach to combatting money laundering. By allowing for a risk-based approach, custodians are able to allocate resources efficiently and direct their efforts to those customers and areas that pose the higher risk. This risk-based approach is articulated in the 2007 report titled “Guidelines on the Risk-Based Approach to Combatting Money Laundering and Terrorist Financing” issued by the Financial Action Task Force (FATF). In this report, it has been noted that where the same standard is set for all customers and resources are evenly applied to all, there could be the unintended consequence of the customer identification or other program elements becoming simply a tick the box exercise. Most anti-money laundering regimes around the globe allow for some form of risk-based approach to conducting customer due diligence. Under a risk-based approach it is up to each firm to decide on the specific documents requested, as determined by the client’s AML risk. So while some of the listed documents may be obtained using a risk-based approach, the regulations do not prescribe a specific list of universally required documents and, therefore, custodians may not always hold the same documents for all clients. Most importantly, where a client’s risk is assessed as low, Simplified Due Diligence (“SDD”) applies. This less burdensome set of KYC requirements is appropriate because the majority of custodian’s FII clients are themselves regulated financial institutions or collective investment vehicles, publicly listed companies, regulated employer funds, or government pension funds. As these categories of institutions have qualified for this SDD, there is no requirement to obtain the detailed documentation listed above. However, custodians must obtain suitable evidence to document the categorization of these clients for SDD.
Risk-based Assessment. The Division Office will conduct a risk-based assessment of the pre-screened projects using the resource deployment tool that emphasizes the ten risk areas below.
