Due Diligence

Financial institutions must be vigilant in managing customer risk, understanding emerging products and markets, and utilize internal and external information to know its customer.  Calibrating a due diligence program is critical to maintaining prospering business lines, but also meeting regulatory expectations. Our services include:

  • Due Diligence – Onboarding – High Risk/MSB/Digital Currency/FinTech/Special Client: Assess the risk and sufficiency of high risk, MSB, FinTech, Digital Currency, and special client relationships compliance program and operations to determine banking compatibility
  • Due Diligence – Monitoring – High Risk/MSB/Digital Currency/FinTech Special Client: Assess the risk and sufficiency of the company’s compliance program, where required, and operations to determine to mitigate risk and customer retention
  • Due Diligence – De-Risking: Develop and execute de-risking strategy for financial institutions

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.