Representative Engagements: Global Financial Crimes Compliance
- Conducted an independent, risk-based assessment of the US branch of a large global banking institution and its Anti-Money Laundering (AML) operations pursuant to a Consent Order. Operating as an approved consultant by the Federal Reserve and New York Department of Financial Services (DFS), Treliant provided services including a global Office of Foreign Assets Control (OFAC) review and identification of high-risk activity.
- Reviewed and improved the AML/Bank Secrecy Act (BSA) program of a New York-based international financial institution. Improvements were made to its compliance practices to develop and implement policies, procedures, and internal controls. A risk assessment was also conducted, resulting in a program that is compliant with the Board of Governors of the Federal Reserve System and New York DFS regulations.
- Conducted an AML/BSA review for a mid-sized financial institution on the East Coast. Services included an AML/BSA policy review; review of the existing AML, BSA, and OFAC risk assessment methodology; evaluation of the Customer Identification Program (CIP); review of policies and procedures related to Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs); and a review of model validation implementation and remediation efforts.
- Performed a co-sourced AML/BSA and OFAC independent review. Services included reviewing written policy and procedures, risk assessments, training records, transaction testing of required recordkeeping provisions including Enhanced Due Diligence (EDD), SARs, Monetary Instrument Logs, CTR Exemptions, Wire Records, Customer Identification Records, and model validation testing.
- Conducted a comprehensive AML/BSA training program for a major Asian bank regarding its AML and BSA practices through sessions with the Board of Directors, branch personnel, head office, customer-facing personnel, loan servicing personnel, and the AML/BSA department, resulting in company-wide understanding of new AML/BSA regulations.
- Provided third-party reviews for a small bank regarding its compliance and risk practices, including a comprehensive review of the bank’s AML/BSA Compliance Management System and OFAC procedures, resulting in steps to ensure compliance with the Federal Financial Institutions Examination Council (FFIEC), Federal Deposit Insurance Corporation (FDIC), and other federal regulatory bodies.
- Conducted an independent model validation of the customer risk model for the North American subsidiary of a global financial services provider. Treliant provided recommendations to enhance the bank’s AML/BSA policies and risk assessment procedures.
- Conducted multiple compliance program enhancements for a regional bank by assessing its model validation program and determining how to implement a leading commercial model for analyzing financial crime risk.
- Conducted multiple internal AML/BSA audit reviews for a Top 20 US Bank. Treliant consultants acted as “auditors in charge” for reviews of the bank’s Automated Clearing House (ACH)/Electronic Data Interchange (EDI) and Business Capital Lending program audits, which included instituting AML-related controls.