Services

Policies and Procedures

There is a natural hierarchy, a structure, to the documents that govern how a financial institution measures, manages and mitigates its compliance risk. At the top of this hierarchy sits the corporate risk tolerance statement, providing a target…

Risk Assessment

The basis of sound and efficient AML, Sanctions and Anti-Corruption compliance programs is a thorough, detailed risk assessment. All assessments should quantify the risk arising from an institution’s customer base, geographic footprint of…

Program Review

There are a number of possible triggers for a broad assessment of the appropriateness and completeness of a financial crimes compliance program. For the last several years, independent program reviews have been prominent features of…

Training

An ongoing employee training program is one of the four pillars of a Bank Secrecy Act/AML compliance program, a pillar that continues to attract the attention of bank examiners. Traditionally, AML training was an annual event, usually using…

Compliance Testing

Compliance departments, particularly financial crime compliance departments, are subject to multiple levels of testing. Internal Audit reviews are a pillar requirement of the Bank Secrecy Act, as are annual assessments by the financial institutions…

Data Quality Review

It all comes down to the data. An institution’s data sets are often a reflection of the history of the institution. As an institution grows over time, as it upgrades or replaces older systems for newer systems, as it buys branches or portfolios of…