We conduct independent testing, assess risk and improve BSA/AML compliance programs
Our BSA/AML Consulting Services are based on experience and demonstrated expertise. We deliver these services in a customized way to meet your needs.
Experienced Professional | Responsive Partners | CAMS Certified
Bank Secrecy Act/Anti-Money (BSA/AML) Laundering compliance reaches into virtually all corners of the financial services industry. The penalties resulting from non-compliance with these requirements are too high to be taken lightly. ADI’s BSA/AML Consulting Services are based on experience and demonstrated expertise. We deliver these services in a customized way to meet your needs, whether large or small. We offer a thoughtful approach based on a clear-eyed assessment of your situation and objectives. Then we design a plan of action and spell out the steps needed to reach your goals. Finally, we work with you to implement that plan. We offer a thoughtful approach based on a clear-eyed assessment of your situation and objectives. We will design a plan of action, spell out the steps needed to reach your goals, and work with you to implement the plan.
Expanded U.S. financial regulations, including terms under which the Office of the Comptroller of the Currency (OCC) will issue and enforce Matters Requiring Attention (MRAs), have led to increased scrutiny and enforcement efforts by the regulators. As a result, more and more banks and financial institutions have faced mandates for internal investigations and action, often within very tight deadlines. ADI helps clients develop and implement corrective action plans that support long-term compliance efforts and sound operational procedures in the context of these directives.
For many reasons, your organization can benefit from an independent risk assessment of its BSA/AML compliance program. ADI conducts the assessment you need, ahead of examinations and visits, and tells you whether you should be concerned and why. We also tell you what steps are needed to improve compliance and provide the resources for implementing its recommended actions. Staying one step ahead of your examiners is critical to your compliance program’s success.
Helping to develop and institute an effective BSA/AML program is the first part of the challenge. Ensuring that that program meets its objectives year in and year out is the second part. ADI helps you meet your obligation to conduct annual independent testing of your BSA/AML program. We tailor an effective testing program to fit your organization, execute the testing in a constructive way, and document the results in a manner that promotes program improvement.
Automated transaction monitoring software implementation is one of the first steps in enhancing your AML suspicious activity monitoring program. But how will you assess whether initial parameters, thresholds, rules, and scenarios you’ve selected, or need to select, are appropriate or are generating too many false positive alerts? Are you missing important data that would aid in your investigations, analysis, and risk scoring of your customers? ADI offers ongoing support with the implementation of AML transaction monitoring applications, as well as overall system assessment and software tuning services. Whether you are setting up your system out of the box or need assistance with system tuning, we help ensure that your system is functioning in a way that aligns with your institution’s risk profile and staff resources.
There are many benefits of risk scoring to identify the level of risk associated with a new customer or account by efficiently capturing CDD information during onboarding and ongoing monitoring. Use of due diligence information can generate an initial score for each new customer/account and ongoing transaction data from monitoring systems can build and continuously update the customers risk score within a “Risk Profile” for each customer or entity. Of particular significance is the ability to identify high-risk customers and establish a scoring framework that provides for account risk scores to decrease or increase as their activity type, volume, and geography changes. ADI can assist in establishing an effective risk scoring system that adheres to current regulation, guidance, and sanctions. If your institution has an established risk scoring system, ADI can review its methodology and offer recommendations to improve upon it, where applicable.
Your institution’s SARs contain useful information, including types of suspicious behaviors, the characteristics of the parties involved, and staff detection methods. Capturing that information in a database and then mining it using analytical tools and techniques, may reveal a better understanding of the underlying activity – the nature of suspicious activity being uncovered, potential patterns and trends, the effectiveness of detection scenarios, overlaps between scenarios, and other opportunities to improve scenarios, to name a few. By restructuring such existing information and using analytics to investigate it, new ways of improving your automated compliance systems may be uncovered. ADI can use, or help you use, analytic tools to data mine your SAR and alert activity to aid in improving the quality and effectiveness of your BSA/AML compliance management system.
Your organization’s policies and procedures must meet two goals:
- Stay current with changes in regulations, regulatory guidance, and industry experience, as well as with business processes, new markets and products, and new information systems.
- Be accessible to and used by employees
ADI assesses the current state of your policies and procedures, designs the enhancements you need for this critical part of your compliance program, and works with you to implement them. Whether drafting your policy from scratch or routinely reviewing and updating it, ADI can assist in ensuring that your policy reflects current regulation as well as your organization’s specific compliance procedures.
Every compliance program needs effective employee training regarding BSA/AML. In general, the anti-money laundering responsibility of the organization should be communicated to every employee, and those people whose jobs place them in a specific risk category should be aware of how mandated reporting and responsibilities apply. This training should be reviewed periodically, especially when people change jobs. Senior management and your institution’s Board of Directors should also receive enough training to model a “culture of compliance” and understand the importance of the internal reviews, audits, and compliance reports they receive. ADI provides BSA/AML training materials, customized for your institution type, compliance department size, employee type, and management level. We can deliver the training to your preference, on-site, via web conference, or online.