Bank Secrecy Act/Anti-Money Laundering compliance reaches into virtually all corners of the financial services industry. For some, these requirements are a burden, yet taken in stride. For others, they are the proverbial square peg in a round hole – no fit has been found. For all, the plethora of penalties resulting from non-compliance are too high to be taken lightly. Team Adhoc’s BSA/AML Consulting Practice is based on experience and demonstrated expertise. We deliver those services in a customized, measurable way to meet your needs.

Advisory

Team Adhoc’s AML practice is the cusp of a multi-decade collaboration between the AML industry’s leading advisory consultants, who have worked closely with financial institutions, regulators and the nation’s top AML advisory firms to help strengthen AML programs since 2003. Unlike competitor firms whose field experience is limited or predates the current AML environment, our management team has extensive and current on-site experience helping retail and commercial banks, brokerage firms, payment services/network operators and credit card issuers hedge AML risk and strengthen internal controls as part of several highly publicized FRB, OCC and NYDFS enforcement actions. Our management team not only possesses the requisite BSA/AML subject matter expertise, it goes beyond evaluating and understanding the gaps between the current and desired state of an AML program in a constantly evolving regulatory environment. In turn, we can assist with the execution of necessary steps to remediate these gaps, as we have done for over 30 clients in the past 13 years.

Temporary Staff Augmentation

By leveraging our existing global network of thousands of AML consultants in diverse Compliance areas, our firm masters the tools to seamlessly facilitate crucial temporary staff needs. Achieving mandatory milestones under tight regulatory time constraints is not accomplished by the incursion of a team unexposed to the industry. Team Adhoc is proud to present proficient industry experts to fulfill myriad Compliance challenges. By working extensively with peer institutions, our firm will aid in efforts to remain ahead of the curve by leveraging industry best practices before they become industry laws.

Areas of Expertise

Our firm leadership and extensive network have assisted financial institutions within the following subject matter areas:

Enterprise-wide BSA/AML risk assessment

  • Business line risk
  • Enterprise-wide risk associated with products, services, customers and geographies
  • Methodology for identifying and quantifying the level of BSA/AML risk associated with various categories of customers
  • Periodic refreshment
  • Comprehensive documentation
  • Enhanced OFAC screening
  • Improved methodology for assessing OFAC risks
  • Enhanced policies and procedures to ensure compliance with the OFAC Regulations

Governance/Board Oversight

  • Governance structure with clear lines of responsibility
  • Clearly defined roles and responsibilities for senior management to oversee compliance with the BSA/AML Requirements and the OFAC Regulations
  • Measures to improve the information reported to the board of directors and its designated compliance committee regarding compliance with BSA/AML Requirements and OFAC Regulations
  • Assessment of the qualifications of the Bank’s BSA/AML and OFAC compliance staff and the adequacy of staffing levels

Customer Due Diligence/Enhanced Due Diligence

  • Determining the appropriate level of enhanced due diligence
  • Special measures for particularly high risk customer types, such as MSBs
  • Addressing systematic deficiencies within customer due diligence processes
  • Policies and procedures for gathering CDD/EDD information for new and existing customers
  • Methodology for assigning risk levels to the Bank’s customer base that assesses appropriate factors such as type of customer, geographic activity, and expected account activity
  • Enterprise-wide customer visibility
  • CIP procedures and process execution
  • Verification of the identity, source of wealth, and business activities of the customer
  • Gathering and documenting anticipated customer transaction activity within various product lines
  • Identification, documentation and screening of accountholders and significant control parties
  • PEP risk
  • Negative news screening
  • Assessing the AML supervisory regime and identifying AML risk associated with the jurisdictions in which customers are domiciled, do business within or transact with
  • Periodic review frequency and tracking
  • Special requirements for correspondent banking relationships including USA PATRIOT Act Certification and Wolfsberg Questionnaire evaluation/tracking and assessment of risk associated with banking customers’ AML programs.
  • Evaluation of the automated CDD/EDD systems of record

Suspicious Activity Monitoring and Reporting

  • Addressing systematic deficiencies within transaction monitoring systems
  • A well-documented methodology for establishing monitoring rules and thresholds.
  • Effective monitoring of customer accounts and transactions
  • Measures to ensure escalation of significant matters to, and documented oversight by, senior management
  • Procedures that indicate the tools or processes to be used in identifying and monitoring high-risk transactions
  • Procedures for investigating and resolving transactions identified as unusual or suspicious
  • Procedures for ensuring sound use of quantitative analysis to support the proper design, implementation and use of models to generate appropriate alerts
  • Processes by which BSA/AML control decisions are escalated to risk management
  • Trends in unusual or suspicious activity that have been identified and reported
  • Quality control/quality assurance
  • Comprehensive and timely alert clearing and SAR reporting
  • Timely and accurate responses to 314(a) and 314(b) requests

BSA independent testing and audit

  • Formal processes to track and report on remediation efforts to strengthen the BSA/AML compliance program
  • Testing of the adequacy of internal controls designed to ensure compliance with the BSA and its implementing regulations
  • A risk-based approach that focuses transactional testing on higher-risk accounts or geographic areas of concern
  • An annual audit with report to the Board of Directors or a committee assessing the condition of the enterprise wide BSA/AML program and opining on the four pillars of the BSA/AML program

BSA Training

  • Development and implementation of a specialized training program for all operational and supervisory personnel responsible for suspicious activity monitoring, investigating, and reporting
  • Strategies for mandatory attendance, the frequency of training, procedures and timing for updating training programs and materials, and the method for delivering training

Historical Transaction Reviews (“look-backs”) and CDD/EDD remediation

  • Evaluate scope of engagement
  • Provide projections regarding production analytics
  • Provide volume staff

Team Adhoc Specialty Solutions

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