Trust Tool- BSA/AML Risk Rating Worksheet: Trust and Estate Accounts
Updated 06/18/2026
This tool is designed to help banks evaluate the potential risks associated with their Trust and Estate Account portfolio. It should be used as part of a comprehensive BSA/AML risk assessment and customized to reflect the bank’s specific risk profile. The document can be customized to meet the specific requirements of the bank’s Trust Department. This document is not a substitute for official legal documentation or BSA/AML required documentation.
Rule: The Federal Financial Institutions Examination Council (FFIEC) BSA/AML Trust and Asset Management Services; FFIEC Appendix J – Quantity of Risk Matrix and Appendix 1 – Beneficial Ownership; Office of the Comptroller of the Currency (OCC) Asset Management Operations and Controls, Financial Crimes Enforcement Network (FinCEN) Guidance (FIN-2016-G003), FinCEN Customer Due Diligence Requirements for Financial Institutions.
Toolkit: Trust
Keywords: Trust Account, Trust and Estate Account Administration, BSA/AML Risk Rating Assessment for Trust/Estate Account(s), BSA/AML Risk Rating Worksheet: Trust and Estate Accounts.
6/18/2026 – Moderate content and formatting revisions made to improve clarity.
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