The Bank Secrecy Act (BSA) and its implementing regulations, most notably the USA PATRIOT Act, defines rules to help detect and report suspicious activities that may be indicators of money laundering. Other regulatory organizations, such as the FDIC, NCUA, and FINRA, have implemented their own rules and guidelines for compliance with the regulations.
Anti-money laundering (AML) programs are required for financial
institutions, money services businesses, investment firms, and other
organizations that may process larger cash (or cash equivalent)
transactions. We are frequently engaged by these organizations to assist
with the evaluation and development of anti-money laundering processes.
Anti-Money Laundering Compliance Programs
We assist organizations with the development, evaluation, and improvement of anti-money laundering compliance programs.
Common improvements include updating the program for new
requirements (i.e. beneficial ownership detection), updating and
augmenting written documentation and development of staff training
We are also engaged in the advent of a regulatory examination to
provide a ‘dry run’ of the inspection and identify defects in the design
and make recommendations for improvement.
We have worked with financial institutions under FDIC memoranda of
understanding to assist them with resolving their compliance issues.
Example Engagement: Regional Bank Review
We were engaged by a regional bank to perform a comprehensive review of their anti-money laundering procedures, including customer due diligence programs, know your customer procedures, AML training programs, and current staff capabilities.
Additionally, we performed a “look-back” review of all accounts and transactions flagged by the bank’s AML monitoring system to evaluate the bank’s capabilities to detect and report potential money laundering in accordance with federal laws. Our work product was submitted to the FDIC to assist with their evaluation of the bank’s procedures and management.