Money Services Businesses (MSBs)
We routinely develop, write and implement compliance programs and conduct risk assessments for Money Services Businesses (MSBs), from small operators, to regional multi-state operations, to nationwide entities, to Foreign Located MSBs (located outside the US and are purely foreign based).
Top 10 Bank Holding company, largest clearing bank of US Dollars in the world
Served as Subject Matter Expert/Project Lead for the development and implementation of a global sanctions evaluation project. Institution was currently operating under several Cease and Desist Orders.
BSA/AML Independent Reviews
We routinely conduct independent reviews of US Branches of Foreign Banks, Community Banks, Money Services Businesses (MSBs), and Prepaid Access (Stored Value) Program Managers.
Central Regulator in Asia
Provided training to examination supervisors as well as policy development guidance regarding the country’s Money Services Businesses enforcement effort.
Leading PrePaid Access program innovator
Provided BSA/AML regulatory consulting in the design and program implementation of a new product launch for the insurance industry.
One of the largest securities firms in the world
Provided design and implementation services for the Private Client Technology (PCT) Group’s strategic architecture.
One of the largest US Insurance companies
Provided consulting assistance for BSA and other regulatory and systems issues stemming from a buyout of a competitors annuity operations business.
A $30 billion dollar asset US Bank
Designed, developed, and tested a risk assessment matrix that was programmed into OTS software for risk scoring of over 40 million customers.
Top 10 US Domestic Retail Banking Institution
Provided remediation under a Cease and Desist Order as a Subject Matter Expert (SME) for Suspicious Activity Reporting and Enhanced Due Diligence programs. Implemented Enhanced Due Diligence procedures for all BSA high risk customer accounts. Our work included development of EDD case management capabilities, risk scoring model validation, development of policies, procedures, workflows, and controls. All work was performed in close cooperation with the bank’s regulator, the OCC.
Top 20 US Domestic Retail Banking Institution
Served as project implementation Subject Matter Expert (SME) for Bank Secrecy Act (BSA) reporting, OFAC and risk scoring products.
A leading investment fund administrator (serving over 300 investment funds, with assets under administration in excess of US$30 billion)
Routinely conduct Enhanced Due Diligence (EDD) on principals of new funds prior to public launch. Provided AML/CFT Awareness training to entire staff.
A large Japanese bank
We were instrumental in implementing systems and controls for Sarbanes-Oxley compliance.
Big Four Public Accounting Firm
Routinely conduct Enhanced Due Diligence (EDD) on clients prior to final acceptance, includes wholly owned subsidiary operates as a Company Management formation agent in an Offshore jurisdiction.
Top 5 Wholesale Banking Institution with Foreign Branches in the US
We assisted in a remediation of AML deficiencies and a merger with another one of the largest financial institutions in the world. We worked closely with the bank at all levels – front, middle, and back office, and acted as liaison with the bank’s regulators, the Federal Reserve Bank and the NY State Banking Department. Remediation work included an enterprise wide risk assessment, USA PATRIOT Act (USAPA) Section 326 Customer Identification Program (CIP) implementation, transaction monitoring system implementation, information sharing software development for Requests for Information (USAPA Sec. 314a search tools), and development of policies, procedures and internal controls for all Bank Secrecy Act (BSA) related functions. We also conducted a look back exercise for the NY branch’s institutional customers, and performed forensic accounting for fraud investigations.
A large NY area foreign commercial bank
Conducted a risk assessment in its portfolio accounting area.
Privately held company specializing in Outsourced Compliance Services
Provided AML training for all employees of various Financial Services Providers on a quarterly basis. The training curriculum was specially developed for each of four distinct staff levels; new and general, frontline/operations, compliance/MLRO, and board of directors/senior management.
Large Regional Money Services Business (branches in 10 states with 100 agents)
Conducted an AML/CFT Review of policies, procedures and operations at the request of the regulator.
Country located in the Caribbean
Assisted in the creation and establishment of a Leading Offshore Jurisdiction and Financial Centre
Largest Bank in a Latin American Country
Conducted an AML Review of policies, procedures and operations at the request of the home country consolidated regulator.
National Police Service and EGMONT Member Financial Intelligence Unit (FIU)
Provided AML training to staff investigators.
AML Product Vendor
Conducted an analysis of competing vendors and products in the marketplace.
AML Product Vendor
Assisted in the product development and enhancement of a high risk database to increase competitiveness and market share.
