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Anti-money laundering enforcement action and remediation
A proactive approach to identifying and remediating weaknesses
Regulatory scrutiny and risk are facts of life for financial institutions. When one or more of the four pillars of a Bank Secrecy Act program is broken, financial institutions often find themselves facing enforcement actions as a consequence. Enforcement actions often mandate the engagement of an independent party to remediate deficient AML program components, investigate previously undetected suspicious activity, and monitor the status and effectiveness of the institution’s corrective action plan.
Proactive engagement with an independent and trusted advisor can significantly improve your institution’s ability to satisfy regulators and avoid unnecessary delays and additional costs due to insufficient remediation actions, repeat findings and additional penalties.
When your institution is faced with an enforcement action, RSM can provide a team of advisors that understands your situation. We work with you to develop and execute a corrective action plan and support business-as-usual operations. Our team has the requisite experience, insight and tools to help your institution effectively address enforcement actions and strengthen compliance processes moving forward.
Improving your governance and program design
RSM’s experienced team can evaluate specific governance, structures, processes and controls within your AML program following an enforcement action, identifying and remediating any weaknesses. We customize our approach to the unique risk profile of your institution and requirements of the enforcement action, focusing on developing and executing a corrective action plan that results in a compliance program that is sustainable and consistent with regulatory expectations and industry standard practices.
RSM services include:
- BSA/AML and Office of Foreign Assets Control (OFAC) risk assessments
- Validation of compliance with remediation plan
- Staffing support
- Program assessments
- Customer due diligence (CDD)/enhanced due diligence (EDD) methodology and processes assessments
- Suspicious activity monitoring
- OFAC and sanctions compliance assessments
Enforcement actions may require “look-back” investigations when significant deficiencies are identified in suspicious activity monitoring, sanctions screening or CDD processes. Banks may need to engage an independent third party to conduct the look-back or supplement staff to maintain business as usual during the look-back process. In addition, necessary program enhancements could result in significant increases in workload, requiring interim assistance until staffing demands stabilize.
RSM utilizes comprehensive data analytics and a case management tool to help your institution efficiently investigate large volumes of customer data, tailoring the investigative focus to the unique risks of your institution and the requirements of the enforcement action.
The RSM advantage
Our resources continuously monitor and interpret the ever-changing expectations around AML enforcement areas to help you stay ahead of evolving issues. Our national AML team works with financial institutions of all sizes and risk profiles, and we have the experience and technology tools to help banks and nonbank financial institutions meet heightened regulatory expectations and mitigate the risks associated with money laundering.