Anti-Money Laundering (AML) Compliance

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

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

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.

Using our proprietary workflow & 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.

We assist internal audit departments in developing comprehensive AML/CFT & sanctions audit programmes, including risk assessments, risk & control matrices, audit work programmes & training for audit teams. We also perform independent testing of existing AML programmes 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. In addition, we also assist in conducting HKMA, SFC and Insurance Authority regulatory reviews and remediations.

We assist in suspicious transaction monitoring and reporting to enable financial institutions to monitor their customers’ transaction behaviour systematically by providing relevant scenarios/rules that analyse the underlying customer transactions and generate automated alerts of activity that may be unusual and indicative of potential money laundering. Our AML experts can also conduct significant work in KYC/CDD space, particularly in relation to source of wealth.

Customised & relevant AML/CFT training provides the basis for a successful AML/CFT & sanctions compliance programme. 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.

We work closely with our data and advanced analytics practice to provide our clients with independent model validation for all AML and sanctions related models, perform AML and sanctions model tuning and threshold /matching score setting, provide advanced data validation and AML analytics, advise on scenario and alert optimisation, and assist with transaction monitoring scenario development, testing, and supporting documentation.