Anti-Money Laundering & Risk Advisory

Financial institutions, money services businesses, securities dealers, etc. are required to maintain an effective anti-money laundering (AML) / Bank Secrecy Act (BSA) program under the BSA that consists of a minimum four elements: (1) policies, procedures and internal controls; (2) designation of a compliance officer; (3) ongoing training; and (4) independent testing (audit).  Moreover, financial institutions and regulatory agencies perform routine independent tests or examinations of their AML/BSA program.

Whether proactively or reactively enhancing an AML/BSA program, Stratis Advisory provides the following services:

  • Infrastructure: Critical organizational infrastructure components, adjustments, and operational evaluations for start-ups through large commercial banks
  • Program Development: AML/BSA Policy and Program Development
  • Risk Assessment: Proprietary risk assessment model for enterprise-wide, business line, or single channel companies
  • Training: AML/BSA/OFAC training for personnel from client-facing through board of directors and delivered by CAMS-certified instructors
  • Due Diligence: Recognize when, where, and how to implement and mitigate client risk
  • CIP/KYC/PEP/OFAC/Risk/TMS Vendor Implementation: Understand the best vendor or calibrate internal proprietary automated CIP/KYC/PEP/OFAC and operationalize these compliance processes
  • Transaction Monitoring: Understand and develop the detection scenarios for monitoring transactions, suspicious activity reporting, and operationalize critical monitoring processes
  • Investigations Program: Evaluate, design, develop, manage, or monitor end-to-end investigations program for efficiency, effectiveness, and compliant documentation and reporting
  • Quality Assurance: Establish QA protocals for complete and accurate business records such as Know Your Customer (KYC) profiles, suspicious activity reports, among others
  • Suspicious Activity Reporting: Investigate, evaluate, and analyze suspicious activity reporting process, quality assurance, case reasoning, and narrative comprehensive for timeliness, accuracy, and completeness
  • Exam Management/Pre-Exam Assessment: Whether prior to, during, or after a BSA examination, identify and understand BSA/AML program effectiveness
  • Independent Test: Perform annual independent test to ensure compliance with the Bank Secrecy Act, anti-money laundering, and sanctions laws and regulations

Contact us for more information.

Engagement Profiles:

MSB Program Enhancements and Risk Assessments for Financial Institution with Global Remittance Portfolio

Situation and Background: Financial institution with global money remittance portfolio under regulatory scrutiny sought enhancements to its MSB program and enhanced risk assessments of remittance clients.

Key Issues:

  • Cross-border remittance portfolio was under scrutiny by banks’ regulator.
  • Bank needed enhancements to its MSB program to establish clear requirements for onboarding and ongoing due diligence.
  • Risk assessments, including transaction analysis, were insufficient based on risk.
  • Portfolio required regular reporting to Compliance Committee and Board of Directors.

Services:

  • Enhanced bank MSB program and procedures that passed regulatory review.
  • Performed enhanced risk assessments, including site-visits of remittance clients to understand AML/BSA risks.
  • Developed in-depth reporting function for remittance portfolio.
  • Presented risk assessment findings with retention recommendations to Compliance Committee and Board of Directors.

AML/BSA Vendor Capability Assessment for Bank

Situation and Background: Global financial institution sought to understand the capabilities of vendors providing compliance services for identity verification, sanctions screening, and transaction monitoring.

Key Issues:

  • Bank needed to understand the existing vendor market for identity verification, sanctions screening, and transaction monitoring for existing FinTech portfolio, including Bitcoin companies.
  • Bank sought to understand what tools Bitcoin companies could use to meet existing AML/BSA compliance requirements.

Services:

  • Initiated and participated in conversations with vendors of KYC/CIP and transaction monitoring solutions.
  • Digested results into a vendor capability assessment.
  • Enhanced client onboarding process with knowledge of vendor capabilities.