Anti-Money Laundering (AML) Compliance

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Protiviti Perspective by Roger Z., Houston

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Given the increasing regulatory scrutiny related to AML issues and complex challenges faced by financial services organisations in that regard, institutions are realising the importance of implementing and maintaining a robust AML program.

In addition, companies are realising the importance of implementing a risk-based Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Compliance Program that can be applied across diverse business lines.

However, evaluating the money laundering risks in an organisation and the tools and techniques available for mitigating these risks can present a significant challenge.

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The core members of Protiviti’s AML Practise are former financial institution regulators, financial institution compliance officers, fraud and forensic specialists, technology experts, and individuals with hands-on experience working in financial institutions of all types. They have considerable experience advising institutions of all types on the design and implementation of their AML/CFT Compliance Programs, conducting independent tests of AML/CFT Compliance Program effectiveness and conducting money laundering investigations.

Protiviti provides a wide variety of consultative services designed to assist organisations in all aspects of AML/CFT compliance, which includes the following areas.

Design and Implementation of AML/CFT Risk and Sanction Risk Assessments

We assist clients with the design and implementation of AML/CFT and sanction risk assessments that are foundational to effective compliance programs. We also work with our clients to ensure the proper alignment between their risk assessments and their overall AML/ CFT and sanction compliance programs and to introduce and leverage innovative technologies to improve efficiency.

Program Development and Remediation

We help clients with the development and/or enhancement of all aspects of their AML/CFT and sanction compliance programs including, but not limited to, risk strategy and risk appetite statements, policies and procedures, job descriptions, staffing analyses, and board and management reporting.

AML/CFT and Sanction System Selection, Implementation and Utilisation

We assist in the selection of technology tools to support ongoing AML/CFT and OFAC monitoring. This includes vendor review and comparison, assessment of current and future business and functional requirements, data lineage and validation, system optimisation, implementation support, pre-and post-implementation reviews, system validation and overall system project planning and management.

Money Laundering Reviews and Investigations

Using our proprietary work flow & data analytics tools, we assist clients in performing regulator-mandated lookbacks & other transaction reviews. We also identify & transactions in-scope, code the desired rules and scenarios, determine through quantitative & qualitative analysis the appropriate thresholds, & generate alerts, which our investigation specialists review to determine whether any suspicious activity is present. Our clients and as applicable, the regulators are provided complete documentation of the work.

DFS Part 504 Compliance

We can assist covered New York State-regulated financial institutions with all aspects of their Part 504 compliance efforts, from internal training & awareness, program development, program management, program documentation, model validation, data lineage and validation, control testing, & design of certification & sub-certification processes.

Independent Testing of AML Programs

We assist internal audit departments in developing comprehensive AML/CFT & sanctions audit programs, including risk assessments, risk & control matrices, audit work programs & training for audit teams. We also perform independent testing of existing AML programs on an outsource or co-source basis & work with or on behalf of internal audit departments to validate actions taken by companies to address regulatory exceptions.

Focused Training

Customised & relevant AML/CFT training provides the basis for a successful AML/CFT & sanctions compliance program. We assist organisations with the development, implementation & delivery of AML/CFT & sanctions training that is customised to reflect a company’s primary business activities, customer profile, current AML/CFT & sanctions knowledge base & internal procedures.