4.3 Identifying the areas of focus for the BMA

Competent authorities should determine the focus of the BMA. They should focus on the business lines that are most important in terms of viability or future sustainability of the current business model, and/or most likely to increase the investment firm’s exposure to existing or new vulnerabilities. Competent authorities may take into account:

• a. the materiality of business activities – whether certain business activities are more important in terms of generating profits (or losses) or cash flows;
• b. previous supervisory findings – whether the findings for other elements of the SREP can provide indicators on business lines requiring further investigation, including findings from AML/CFT supervisors;
• c. findings and observations from internal or external audit reports – whether the audit function has identified specific issues regarding the sustainability or viability of certain business lines;
• d. importance to strategic plans – whether there are business lines that the investment firm wishes to grow substantially, or to decrease;
• e. observed changes in the business model – whether there are observed de facto changes in the business model that have occurred without the investment firm declaring any planned changes or releasing new strategic plans and whether the business model changes may expose the investment firm to increased ML/TF risks; and
• f. peer comparisons – whether a business line has performed atypically (been an outlier) compared to peers.