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Global Financial Crimes Compliance

The proliferation of financial crimes through money laundering, human trafficking, terrorism, bribery and corruption, and fraud is a continuing challenge for institutions of all types and sizes, and geographical footprints.  A robust control infrastructure leveraging sound business processes to both mitigate current risk and emerging risk is required. Complacency is unacceptable to law enforcement and regulators, and will only lead to enforcement activity, including fines against the institution. Shareholders, boards, and senior management need to understand and make the investment required to implement and maintain effective financial crimes programs.  And financial crimes leaders need to know both the requirements and how to effectively implement financial crimes programs.

Treliant’s highly experienced leadership and team of global financial crimes subject matter experts can help you to navigate the rough waters to robust and sustainable financial crimes programs – AML/BSA; Global Sanctions (OFAC); Anti-Bribery/Corruption; Antitrust. Our team of subject matter experts consists of former compliance and internal audit executives and professionals, regulators, federal prosecutors, and other industry practitioners. We have extensive experience in every aspect of financial crimes compliance with all types and sizes of institutions – from small to large – domestic and complex international institutions. Our in-house industry, regulatory, and law enforcement experience, along with our experience as enforcement action monitors, makes for a powerful advisory practice. And we have a reputation for independence and integrity with clients and regulators.

We Know Financial Crimes Compliance and Remediation from the Inside


We understand the business and its operations because we are from the business.  We are uniquely positioned through our extensive global experience and backgrounds to provide robust advisory, assessment, and assurance services.  Our senior subject matter experts have:

  • Built or participated in building and managing financial crimes programs at institutions – community, regional, large, international
  • Led global, multi-faceted enforcement action remediation assessments and assurance engagements
  • Implemented, tested, and validated tools for monitoring and screening

We Know Enforcement Actions and How to Provide Independent Assurance


We bring a broad and deep perspective of what regulators and law enforcement expect through our experience as monitors and independent consultants for institutions under enforcement actions.

We Know How to Test and Provide Assurance on Financial Crimes Compliance Programs 


We are seasoned compliance testers and auditors who have derived our skills from in-business, consulting, and monitorship experiences at all types and sizes of institutions – domestic and international.  Our subject matter experts have conducted extensive compliance testing and assurance work in the U.S. and internationally on:

  • AML/BSA programs
  • Sanction/OFAC programs
  • Anti-Bribery/Corruption programs
  • Antitrust programs

Treliant's Global Financial Crimes Compliance Regulatory Advisory Services Include:

Program Design, Assessment, and Implementation

  • Design and Implementation of Compliance Programs
  • Program Reviews, including Health Checks
  • Department Structure and Staffing Assessments
  • Policy and Procedure Development
  • Acquisition/Merger Due Diligence
  • Risk Assessments
  • Risk Scoring Methodology Development
  • Independent Audits

Customer Risk Profile

  • Customer Segmentation
  • High Risk Customer Methodology
  • Know Your Customer (KYC)/Customer Due Diligence (CDD) Program
  • Customer Identification Program (CIP)        
  • Enhanced Due Diligence (EDD) Program
  • Correspondent Banking Due Diligence

Data Analytics and Remediation

  • Data Integrity/Lineage Reviews
  • Customer Data Quality Reviews
  • Data Acquisition: Normalization

Regulatory Exams

  • Exam Preparation
  • Corrective Action Advisory and Remediation

Program Outsourcing

  • All Program Areas from Oversight to Investigations

Staff Augmentation

  • Staffing at all Levels: Chief Compliance Officer (CCO); Analyst; Auditor

Governance

  • Board of Directors and Senior Management Roles and Responsibilities
  • Management and Board Reporting; Dashboard and Metrics Design
  • Corporate Culture Reviews and Assessments
  • First-, Second-, and Third-Line Roles and Responsibilities       
  • Training at all Levels—Board; Management; Employees

Model Governance, Review, Implementation, and Validation

  • Model Governance
  • Model Documentation Procedure and Analysis
  • Anti-Money Laundering (AML) Alerting Sanctions for Office of Foreign Assets Control (OFAC) Screening Tools Identification and Implementation
  • Anti-Money Laundering (AML) Monitoring Rules/Scenarios, Identification, Calibration, and Analysis    
  • Sanctions (OFAC) Filters/Fuzzy Logic Rules Identification, Calibration and Analysis

Investigations and Lookbacks

  • Financial Investigation Unit (FIU) Review
  • Alert and Case Management Process Review
  • Enhanced Due Diligence (EDD) and Transaction Lookbacks
  • Suspicious Activity Reporting (SAR) Review

Enforcement Action Remediation

  • Independent Compliance Monitorships/Consultancies
  • Independent Compliance Reviews and Audits 
  • Independent Transactional Reviews (Lookbacks) 
  • Tactical Remediation Project Plans

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