The stakes are very high for banks and financial institutions in the bank secrecy/anti-money laundering area. This is why there is a greater than ever need for clarity and plain English when it comes to the requirements.The simple guidelines are:
1)financial institutions should know who they are doing business with 2)and what kind of transactions those individuals or entities are conducting. This requires the requisite amount of diligence up front about the individuals, their business or both. After clients are admitted into the bank or financial institution, regulators require monitoring of transactions to ensure that funds deposited or leaving the institution are not the fruit of, or in furtherance of an illegal scheme. The institutions that do not comply with these requirements may not only be cited for technical violations, but lately have been fined or criminally charged for furthering or aiding and abetting the illegal activity.It is important to have a program that can provide analytics, forensics and other evidence to demonstrate that your financial institution not only knows their clients, but is keenly familiar with their account activity.
The types of controls, processes and analytics required vary based on the nature of the institution. High-risk products and services include substantial volumes of electronic payments or wire transfers, online account opening or services to third-party payment processors or senders. High-risk clients include cash-intensive businesses, foreign entities or politically exposed persons. Finally, there are high-risk geographic locations such as offshore financial centers or High Intensity Drug Trafficking Areas (mostly border states or urban centers) or High Intensity Financial Crime Areas (similar areas).
As such, a sound BSA/AML program begins with a thorough risk assessment. Policies, procedures, controls and processes are developed based upon the business of the financial institution and their customer or client base. One example might be an initial analysis of the type of transactions and the number of high-risk customers. For certain smaller banks with more basic business models, the BSA/AML program may involve basic checking and documentation. For other types of institutions far more elaborate systems and processes might be required.
Alexander Church can demystify this process for you because we inherently understand and have had success with the process. We know the types of institutions involved, the types of clients or prospects involved, and more importantly, understand the controls the regulators need to see in place on a daily, weekly, monthly or annual basis. We do not view our responsibility as to complicate the process to make you overly tentative or overly reliant on outside sources for help. Our job is to educate, train and provide the resources for you so your everyone at your institution is confident in this important in this area and there is far less chance for error.
Alexander Church performs myriad services to meet the regulatory requirements for financial institutions. Among them are:
Independent Testing in Accordance with FFIEC Requriements
Review of and/or Implementation of policies, procedures and controls Employee, Operations, Senior Management and Board of Directors Training Third party vendor review
Alexander Church specializes in BSA/AML matters. For more information please contact us at email@example.com or call 1-888-780-8810.