Investigations / Compliance Consulting

Anti-Money Laundering (AML)

We help clients identify, assess, and mitigate risks associated with money laundering, sanctions, and terrorist financing exposure to proactively ensure legal and regulatory compliance.

We leverage data analytics to assess and optimize critical compliance processes in sync with regulatory expectations and best business practices.

Our Financial Crime Risk Management (FCRM) experts provide specialized expertise in matters involving regulator mandated actions, BAU investigations, targeted transaction, and due diligence reviews.

We evaluate anti-money laundering compliance programs and advise stakeholders in all matters related to a robust compliance framework that includes technology and governance-related practices.

Our Services
  • AML & Sanctions Independent Consultancies / Monitorships
  • AML & Sanctions Model Validation, Tuning & Testing
  • AML & Sanctions Program Reviews
  • AML & Sanctions Risk Assessments
  • AML & Sanctions Training
  • AML Policy & Procedure Design & Implementation
  • Casino & On-Line Gaming Compliance
  • Compliance Data Integrity / Architecture Reviews
  • Crypto Compliance & Investigations
  • Historical Transaction Reviews
  • Independent Testing
  • KYC CDD Remediation / EDD Reviews
  • Managed Services
  • Transaction Monitoring Program Design and Implementation
Our Subject Matter Experts
  • Bank Secrecy Act Specialists
  • Certified Anti-Money Laundering Specialists
  • Certified Fraud Examiners & Investigators
  • Computer Forensic Experts
  • Financial Analysts
  • Forensic Accountants
  • Former Chief Compliance Officers
  • Former FBI & Law Enforcement Intelligence Analysts
  • Former Financial Institution Regulators
  • Former Government Agency Professionals
  • Former In-House & General Counsel
  • Former Prosecutors
  • Senior Industry Executives
Anti-Money Laundering Investigations

Our team is retained by organizations to identify and mitigate risks associated with complex banking and crypto products in alignment with regulatory expectations to stem the flow of illicit funds through the financial system. We leverage technology and analytic expertise to offer practical solutions in risk mitigation and aligned with regulatory priorities.

AML & Sanctions Program Development, Implementation & Training

Our experts work with clients to develop BSA/AML programs that will exceed regulatory scrutiny and mitigate risk to the institution, in alignment with business operations. We work with clients to align BSA/AML policies and procedures with the institution’s specific business model, industry, and growth trajectory.

Our team also works with relevant stakeholders within an organization to develop an appropriate AML and/or Sanctions training program, including both general and highly tailored training materials.

Program Reviews

We evaluate AML and sanctions programs for organizations of all sizes, from global bank to start-up, to ensure compliance with regulatory requirements and industry best practice.

Our experts provide strategic analysis regarding financial crime compliance programs including risk identification and management, governance, Know-Your-Customer (KYC) policies, resource allocation, technology enablement, training, and reporting.

By evaluating internal programs through lookbacks and providing gap analysis to identify deficiencies in an organization’s AML procedures, our experts help clients mitigate their risks and exposure to regulatory penalties.

AML & Sanctions Risk Assessments

In collaboration with the client, our experts develop a risk assessment customized to the organization’s unique needs. The risk assessment is designed to aid in the identification of inherent AML and/or sanctions risks, associated with products, geographies, or customer characteristics and the strength of the controls in place to mitigate those risks.

AML & Sanctions Model Validation, Tuning & Testing

Our experts perform pre- and post-implementation AML & Sanctions model validation(s), tuning, and testing to evaluate the efficacy and soundness of the model design, as well as the model’s ability to appropriately detect unusual or potentially suspicious activity. Our model validation testing activities are designed to be consistent with J.S. Held’s understanding of applicable supervisory guidance on model risk management contained in OCC Bulletin 2011-12/ FRB SR 11-7 for the model areas tested which include:

  • Conceptual Soundness
  • Data Quality / Data Lineage
  • Model Implementation Accuracy
  • Model Governance
  • Tuning & Recalibration Processes
  • Outcomes Analysis & Model Governance
Transaction Reviews & Monitoring Programs

Our experts conduct independent investigations and analysis to ascertain whether transactions are potentially suspicious in nature or violate OFAC requirements.

We provide technical expertise in historical transaction reviews to determine the full extent to which an absence or failure of proper AML controls could have resulted in potential violations. We assist clients in the ETL process, alert screening, and the disposition and reporting of results. Our team is highly experienced in both voluntary and regulator-driven historical transaction reviews and has assisted organizations globally in analysis of transactions and filing of Suspicious Activity Reports.

We also help our clients to implement and maintain healthy, ongoing Transaction Monitoring programs. Our Transaction Monitoring program implementation includes guidance on governance, reporting, coverage strategy and rule selection, rule implementation, and rule threshold tuning justification(s).

Outsourcing Services / Managed Services

Our team assists in-house compliance professionals by supplementing their existing AML compliance programs. We work with an organization’s compliance teams to streamline the investigative process and identify enhancements to improve productivity. We offer guidance to organizations regarding BSA/AML regulatory compliance as well as improvements to internal systems and processes.

Our experts can be engaged on a long- or short-term basis for both low level false positive review at the alert level or complex investigations at the case level. We enable organizations to reduce costs, streamline compliance team bandwidth, and meet industry best-practices for alert clearing and BSA/AML reporting.

Compliance Data Integrity & Architecture

Our experts assist institutions in all aspects of data lineage responsibilities that have downstream BSA/AML impacts. We help to mitigate data-related risks by providing guidance in the following areas:

  • Data Intelligence & Augmentation
  • Data Transformation & Enrichment
  • Evaluation, Design & Implementation
  • Machine Learning & Engineered Algorithm Integration
  • Process Automation
  • Reporting & Visualization
  • Transformation Advisory & Management
Casino & Online Gaming Compliance

Our team assists entities in the gaming industry to meet the robust BSA/AML regulatory requirements associated with their business operations.

We deliver specialized expertise from BSA/AML compliance program implementation to providing technological guidance to help gaming organizations make effective, well-informed decisions.

Our experts hold the distinction of being selected as the first BSA/AML compliance monitor in the gaming industry. This monitorship was court-appointed and lasted for three years.

Cryptocurrency Compliance Services & Investigations

We help clients achieve and ensure compliance as new regulations are implemented in the complex, quickly evolving cryptocurrency landscape. Our experts work with clients to develop anti-money laundering programs related to transactions and investments in cryptocurrency and offer comprehensive analysis in cryptocurrency investigations through asset tracing and determination of source of wealth, source of funds, and provenance.

We provide strategic guidance to clients in acquiring U.S. banks accounts, help to create a centralized KYC subscription-based repository on a blockchain, and offer expertise in licensing matters.

Click here to learn more about our cryptocurrency expertise.

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