Anti-Money Laundering & Sanctions

Objective, forward-thinking partnership

We have been examining compliance risk management in relation to the Bank Secrecy Act (BSA), AML and the Office of Foreign Assets Control (OFAC) for many years.  Our experience extends to risk assessments and statutory reviews, benchmarking against international best practice, and tailoring our recommendations to jurisdiction-specific requirements and local regulations.

We have guided clients through every phase of identifying financial crime threat patterns: trends, typologies, and correspondent banking activities.  By extracting and analyzing large data sets, we provide insight and recommend enhancements in various areas:

• Independent reviews and risk assessments of AML/CTF programs
• Customer Due Diligence and Enhanced Customer Due Diligence
• Know-Your-Client (KYC) measures
• Determining Beneficial Ownership
• Suspicious transaction monitoring arrangements
• Financial crime risk identification, mitigation and management
• Quantifying the economic impact of risk
• Whistle-blower procedures
• Organizational culture and misconduct
• Responding to Regulators

Global Financial Industry and Sanctions Experts

We have a broad footprint of cross-discipline experts, including former investment bankers, with over 25 years of experience in top-tier investment banks, as well as former regulators at OFAC. They work alongside forensic accountants, financial analysts, software engineers, and eDiscovery and data analytics experts to deliver tailored services to our clients. Our team also includes several Certified Anti-Money Laundering Specialists (ACAMS).

Whether helping clients respond effectively and thoroughly to, regulatory subpoenas or serious whistleblowing allegations to developing a bespoke compliance program framework, mapped against all leading international benchmarks, we have the expertise, anywhere in the world.  

Compliance Expertise

We have served as an independent compliance monitor and also supported compliance monitorships appointed by the US Department of Justice (DOJ), US Securities and Exchange Commission (SEC), Public Company Accounting Oversight Board (PCAOB) and New York Department of Financial Services (NYDFS) on a number of matters. We have been involved in monitorships related to anti-bribery and corruption, anti-money laundering, Office of Foreign Assets Control (OFAC) sanctions violations, fraud, and PCAOB accounting and auditing standards. We have also assisted clients operating under Deferred Prosecution Agreements (DPAs) in preparing for and interacting with compliance monitors. In this capacity, we have been responsible for the assessment, design and/or monitoring of compliance policies and procedures.

Litigation and Arbitration Support

Our seasoned experts have extensive and specialised experience in the financial services sector. Combined with our multi-disciplinary approach, we can analyse complex funds flows, review correspondence and accounting records, and quantify losses. We are able to provide crucial evidence in high profile, multi-jurisdictional matters, combining our strong accounting knowledge and financial modeling skills with expert knowledge of banking systems and data mining. Our team members frequently provide expert reporting and expert testimony in financial disputes and compliance matters.

Data Analytics in Banking and Sanctions

Bank data exists in numerous siloed systems from trading platforms and payment systems to Know-Your-Client (KYC) and core banking. Leveraging the right data and applying the right analytic techniques for financial crime initiatives not only optimizes detection efforts but also enhances monitoring and prevention capabilities, as well as creating vast opportunities to identify operational efficiencies, cost savings and enabling better customer, business and risk insights. In addition to alert screening systems (e.g. AML, sanctions, etc.), analytics led monitoring enhances a bank’s compliance capability and de-risks siloed systems and data.

FRA’s sanctions analytics tools combine our sanctions investigations experience with our understanding of sanctions lists and banking operations. These tools, such as our historic sanctions search engine, enable rapid identification in third-party interactions and trans-actions/payments deemed to be potential sanctions violations.