Enterprise-wide BSA/AML Compliance Program
We can help your organization to
(1) implement an enterprise-wide BSA/AML compliance program for specific
compliance functions; (2) assess your institution’s BSA/AML risk on a
consolidated basis across all activities; and (3) develop risk-based policies,
procedures and processes from your organization’s risk assessment.
Risk Assessment and BSA/AML Compliance Program
We will identify and measure the
risk associated with your organization’s products, services, customers and
geographic locations.
We will evaluate your
organization’s BSA/AML policies, procedures, systems, and internal
controls; and determine the adequacy of your organization’s risk-based
BSA/AML compliance program.
Correspondent Accounts (Foreign)
We will assess the adequacy of
your organization’s systems to manage the risk associated with foreign
correspondent account relationships, including management’s ability to
implement effective due diligence, monitoring and reporting systems.
Trade Finance Activities
We will assess the adequacy of
your organization’s systems to manage the risks associated with its trade
finance activities, and its management’s ability to implement effective
due diligence, monitoring and reporting procedures and practices.
Private Banking (Non-US Persons)
We will assess your
organization’s compliance with the regulatory requirements to implement
policies, procedures and controls to detect and report money laundering and
suspicious activity through private banking accounts established, administered
or maintained for non-US persons and shall recommend or assist to implement
corrective measures if necessary.
We will assist your organization
in assessing the presence of any potential risk on an account by account basis
and establishing account activity baselines to facilitate the detection of
suspicious activity and the identification of accounts warranting additional
scrutiny.
Independent Testing for Compliance
We will conduct an annual
independent review and testing for compliance and provide a comprehensive
report that includes but not limited to: (1) the scope of the review and
independent testing; (2) an evaluation of your organization’s BSA/AML
program components (e.g. customer identification program, OFAC, BSA
recordkeeping, information sharing, internal routine and controls, integrity
and accuracy of the institution’s information and communication systems,
Board and senior management oversight, training, transactions monitoring, and
suspicious activity reporting); (3) testing with the use of statistical
sampling methods; and (4) risk rating of your institution’s BSA/AML
compliance condition based on rating categories used in the industry.
Training
We will assist your organization
to address the critical elements of an effective BSA/AML training program. In
this regard, we will design the training program and implement it by providing
hands-on on-site training for selected personnel and functional arrears.
Suspicious Activity Reporting
We will assess your
organization’s policies, procedures, and processes, and its overall
compliance with statutory and regulatory requirements for monitoring, detecting
and reporting suspicious activities.
We will review your
organization’s currency activity reports, significant balance change
reports, funds transfer and monetary instrument records, law enforcement
inquiries and requests any responses to them, the SAR decision making and Board
notification processes, SAR quality, timely filing, and record
retention.
Office of Foreign Assets Control (OFAC)
We will assess your
organization’s risk-based OFAC program to determine its adequacy for the
organization’s OFAC risk, taking into consideration its products,
services, customers, transactions and geographies.
We will evaluate the
effectiveness of your organization’s internal controls for identifying
suspect accounts and transactions and reporting to OFAC.
Money Services Businesses (MSBs)
We will (1) assist your company
to license and register as a MSB at the state and federal levels; (2) prepare
BSA/AML policies and procedures customized to the specific activities of your
MSB; (3) develop training program’s for your company’s personnel; (4)
assist with compliance and regulatory issues; and (5) assist in identifying a
financial institution that may be interested in providing services to MSBs.
We will also (1) conduct BSA/AML
risk assessment of your MSB’s customers, products and services, and
geographies; (2) review and test your MSB’s compliance with anti-money
laundering/anti-terrorist financing laws and regulations; and (3) prepare
comprehensive reports for submission to your MSB’s existing and
prospective banks, if required.
Broker-Dealers
NASD Rule 3011 requires every
NASD member firm to develop and implement a written AML program reasonably
designed to achieve and monitor the firm’s compliance with the BSA and its
implementing regulations.
We will (1) perform the required
independent testing for compliance; (2) monitor, on an ongoing basis, for
unusual transactions; (3) conduct BSA/AML training and (4) assist in designing
and updating your firm’s BSA/AML program.
Financial Intelligence Units
Financial Intelligence Units
(FIUs) are national agencies responsible for receiving, analyzing and
transmitting disclosures on suspicious transactions to the competent
authorities in the jurisdictions they operate. FIUs are owned and operated by
foreign governmental agencies.
We will assist these agencies to
(1) establish FIUs, (2) define the FIUs’ core and other functions; and (3)
assess and enhance the effectiveness of existing FIUs.
Consumer Compliance
We will (1) develop a compliance
manual which includes the coverage of each regulation or statute, your
institution’s compliance policies, procedures, and compliance management
systems; and (2) assist in the training of compliance personnel and
implementation of the consumer compliance program.
CARICOM Trade Support Program
We are registered as a
consulting firm with the CTS program (www.caricomtradesupport.org). We will (1) provide consulting
support services or technical assistance to eligible CARICOM companies; and (2)
assist in identifying financial institutions in the US interested in extending
US Export-Import supported credit facilities to qualified CARICOM companies
importing US manufactured goods, and US services.
Automated Teller Machine Systems
Turnkey card issuing and
acquiring systems: We will implement turnkey card issuing and card
acquiring systems for the introduction of major credit and debit cards and the
upgrading of these processing systems.
Advise on organizational
change: We will provide your organization’s management, business
processes re-engineering and advice on organizational change warranted by the
introduction of new systems and processes. Feasibility studies, project
management and implementation of these systems and processes are also services
that we will provide your financial institution.
|
