For argument's sake, let's say the morning paper carries a big headline about a money-laundering case involving a leading financial institution in another country. It just so happens that you, as compliance officer, are in the midst of updating your bank's Bank Secrecy Act/Anti-Money Laundering risk assessment. So, you are confronted with a series of choices: Should this headline be factored into your assessment revisions? If so, would the bank's business with companies doing business with or in that country or its companies be affected? Would business conducted by consumers be affected? Or would all transactions connected with that nation be impacted or exposed sufficiently to cause you to classify such transactions as "high risk," and therefore subject to special procedures and treatment under the bank's program?
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