Given the increasing regulatory scrutiny related to AML issues and complex challenges faced by financial services organizations in that regard, institutions are realizing the importance of implementing and maintaining a robust AML program. In addition, companies are realizing 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 organization and the tools and techniques available for mitigating these risks can present a significant challenge.
The core members of Protiviti’s AML Practice 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.
We assist organizations with the development, implementation and delivery of AML/CFT training that is customized to reflect an organization's primary business activities, customer profile, current AML/CFT knowledge base and internal procedures.
Design and Implementation of AML/CFT Risk Assessments
An effective and complete AML/CFT Compliance Program considers the business and customer profile of an institution. We can review the institution’s business, customers and transactions to identify areas with high potential for exposure to money laundering and/or OFAC violations.
Program Development, Implementation and Review
AML/CFT risk management requires companies to identify, measure, control and monitor money laundering risk effectively. Our professionals have assisted and continue to assist a variety of clients with developing and implementing comprehensive AML/CFT Compliance Programs that address the latest regulatory and industry expectations and the company’s own unique money laundering risk. This includes documentation of the AML/CFT Compliance Program in the form of customized policies and procedures.
AML/CFT System Vendor Selection and Utilization
We assist in the selection of appropriate technology tools to support ongoing AML/CFT and OFAC monitoring. This includes current and future requirements, vendor review and assessment scorecarding, project planning and management, implementation support, system tuning and system validation.
Model Assessments and Data Validation for AML/CFT Systems
We perform independent assessments of AML/CFT and sanctions-related models, which include assessment of an institution’s model governance, evaluation and tuning of scenario and threshold settings, and validation of data sourced for the models.
OFAC Sanctions Compliance Program Design and Reviews
We work with a variety of organizations to review existing OFAC Sanctions Compliance Programs and make recommendations for enhancements. We also assist in the development, implementation and documentation of an effective OFAC Sanctions Compliance Program.
Money Laundering Investigations
Money laundering schemes are becoming increasingly sophisticated and complex. Our professionals identify the flow of funds from originator to ultimate beneficiary and identify the parties and the financial institutions involved. We identify the types of instruments used in the scheme(s), determine the amount of funds involved, and identify relationships between related parties. We trace assets through the financial system and assist with their ultimate recovery.
Independent Testing of AML Programs
We perform independent testing of existing AML Programs, including a review of written AML/CFT policies and procedures, the AML/CFT training program, and AML/CFT-related technology reviews. We also perform selected transaction testing and provide recommendations for enhancements.
Should your organization become the subject of an enforcement action, we can assist you with identifying the root cause and magnitude of the issue, and the improvements necessary to prevent recurrence; negotiating regulatory agreements; developing and implementing corrective action plans; and liaising with regulatory agencies and/or outside counsel.