Bank Leumi

Challenge

FRA was engaged to support the monitorship of an Israeli bank and its subsidiaries, who between 2000 and 2011 were found to have willfully assisted US clients in opening and maintaining undeclared accounts in a foreign country, and concealing offshore assets and income from authorities. Post-settlement, FRA served as the forensic consultant to the appointed independent compliance monitor under the terms of a Consent Order. The monitorship involved conducting a comprehensive evaluation of the bank’s global compliance function.

Action

FRA designed and executed compliance-focused data analysis and testing of relevant aspects of the bank’s compliance program, as related to US Department of Treasury’s Office of Foreign Assets Control (OFAC), US Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) and the Foreign Account Tax Compliance Act (FATCA), and assisted in the assessment of the bank’s corporate governance across multiple jurisdictions. The assessment included interviews with key members of the compliance and AML teams, evaluation of the Know-Your-Customer (KYC) program, Enhanced Due Diligence procedures, customer risk rating systems, and transaction monitoring and reporting systems. FRA’s analysis and testing of data from multiple disparate bank systems was performed under strict data privacy and security protocols agreed with the bank.

Solution

FRA’s analysis enabled the monitorship team to develop a series of practical and realistic recommendations — at both the global and local level — for the bank to implement in support of strengthening its global compliance program.