An effective compliance program starts with an evaluation of the compliance risks specific to a bank's operations and structure. To ensure an appropriate risk-based compliance program, ICS will:

• Identify specific laws and regulations applicable to each business unit
• Review existing compliance documentation
• Evaluate compliance policies and procedures
• Test transactions in selected operating departments
• Interview key personnel from each business unit
• Ascertain compliance systems and controls
• Evaluate compliance training efforts

The results of this risk assessment will be used to analyze the strengths and weaknesses of the bank's current compliance program, and then to recommend an enhanced, comprehensive program, to ensure the effective deployment of the bank's resources to the compliance issues of greatest risk.