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Global Financial Crimes Compliance

More than 40 years after the creation of the Bank Secrecy Act (BSA) of 1970, Anti-Money Laundering (AML) continues to be a top priority for banks and non-bank financial institutions of all sizes. Steering clear of enforcement actions through sound risk management principles and practices while balancing internal cost control initiatives has become more challenging than ever. Compounding these obstacles are the speed and complexity by which money laundering and terrorist financing activities are being carried out. As institutions continue to expand the ways in which they interact with their customers, so, too, do they create new mechanisms by which illegal activity may be carried out.


Treliant’s Anti-Money Laundering practice takes a holistic, risk-based approach to helping organizations design, implement, and enhance all aspects of their AML program. Our practitioners provide a 360° compliance view by bringing a team of former examiners and compliance officers together with enterprise risk management and consultative perspectives.


Our AML services are built around Treliant’s AML model, which leverages guidance provided by the Federal Financial Institutions Examination Council (FFIEC) and provides organizations with a succinct framework to assess and articulate the core components and critical dependencies of their AML program to regulators, the Board, senior management and AML risk owners across the enterprise. The model is customer centric, grounded in an organization’s BSA/AML risk assessment and supported by appropriate governance, knowledge management, controls, and data analytics.


Treliant’s Global Financial Crimes Compliance Advisory Services include:

Enforcement Remediation

  • Independent Compliance Reviews and Audits
  • Compliance Program Design and Implementation
  • Independent Transactional Reviews (Lookbacks)
  • Coordination of Legal Services through Leading Law Firms
  • Tactical Remediation Project Plans 
  • Independent Compliance Monitorships

Program Assessment, Design, and Implementation

  • Assessments and Reports on the Effectiveness and Health of Compliance Programs, including through Independent Audits
  • Design and Implementation of Compliance Programs
  • Department Structure and Staffing Assessments
  • Policy and Procedure Development
  • Acquisition Due Diligence

Regulatory Exams

  • Exam Preparation
  • Corrective Action Advisory and Validation

Staff Augmentation

  • Staffing at all Levels—CCO; Analyst; Auditor

Risk Assessment

  • AML/BSA Risk Assessment
  • Sanctions/Office of Foreign Assets Control (OFAC) Risk Assessment
  • Anti-Bribery/Anti-Corruption Risk Assessment
  • Risk Scoring Methodology Development
  • Risk Appetite and Tolerance Statements

Customer Risk Profile

  • Perform Examination Readiness Reviews

Governance

  • Review Cross-Border Impacts of Markets in Financial Instruments Directive II (MiFID II) Regulations on US Trading Operations
  • Review Preparation for and Compliance with Investor Protection Requirements
  • Review Preparation for and Compliance with Rules on Trading Venues, Algorithms, Pre- and Post-Trade Transparency, and Internal Matching and Crossing Trades
  • Review Adequacy and Effectiveness of First- and Second-Line Controls Required by MiFID II

Suspicious Activity Monitoring and Reporting

  • Perform Third-Party Review of eCommerce Pricing and Algorithm Codes
  • Provide Support and Enablement of Compliance Review Algorithms in Pricing
  • Provide "Harm Simulation" Capability to Evaluate Effectiveness of Trade Surveillance
  • Review Methodology and Rules Against Requirements for Best Execution and Far, Clear, and not Misleading Standards
  • Assess Adequacy of Model Documentation and Periodic Testing

Alert Management

  • Financial Investigation Unit (FIU) Development
  • Lookbacks and Alert Reviews
  • Customer Name Screening (Sanctions, Negative News, etc.)

Data Analytics

  • Data Integrity Reviews
  • Customer Data Quality Reviews
  • Sanctions Filters—Fuzzy Logic

Model Identification, Validation, and Governance

  • Alerting Systems Identification, Implementation, and Advisory
  • Outcome Analysis
  • Model Documentation

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