AML RightSource also offers a number of BSA/AML Consulting services. Our professionals are experienced in assisting financial institutions (banks and credit unions alike) in the areas of BSA/AML Program Design; development of written Policies & Procedures; performing Risk Assessments; and conducting Look-Back reviews. We have provided consulting services for these items as well as other BSA/AML related topics such as KYC, CIP and OFAC to a number of financial institutions. We have also worked with several institutions who have been hit with an Enforcement Action such as a Cease & Desist order. In many cases, we used our expertise to help our client redesign their BSA/AML program in a way that not only strengthened it (to the delight of their regulator), but did so in an efficient and affordable manner.
We also work with institutions to assess and implement an effective and affordable transaction monitoring program. In some cases this may involve an outsource solution to the transaction monitoring need, but can also include the determination to implement software. In the case where software is the solution of choice, we utilize our experience and expertise in having worked with numerous software providers to help the institution select the software that best meets their needs and then assist in the implementation phase to make the conversion as painless as possible.
Our consulting services also extend to the non-traditional financial institution, such as Money Service Businesses, Insurance Companies, Mortgage Brokers and Private Equity groups.
If you have a need for expertise in with a BSA/AML related matter, we encourage you to give us a call or submit and inquiry to info@AMLRightSource.com
The following examples illustrate how our consulting services have assisted our clients:
Traditional Financial Institution
AML RightSource was contacted by a $10 billion asset size institution that was facing a Cease & Desist from it regulator for a deficient BSA/AML program. AML RightSource provided consulting services to the institution that included (1) a comprehensive review, analysis and enhancement of institution’s BSA/AML program, (2) an analysis and re-write of the institutions BSA/AML policies & procedures, (3) development and preparation of a comprehensive internal risk assessment, (4) review and enhancement of OFAC, 314(a) and PEP procedures, and (5) investigation and recommendation of transaction monitoring options.
During the C&D process, the institution was precluded from making and further acquisitions, which put its strategic plan on hold. However, once AML RightSource completed the consultative side of the engagement, it quickly went to work on helping the institution implement the recommendations agreed to by their regulator. Shortly thereafter, the regulator rescinded the C&D and the institution was allowed to continue on the acquisition front.
Non-Traditional Institution – MSB
AML RightSource was retained by a newly created entity that had the strategic object to establish a licensed Money Services Business for the sole purpose of importing and selling foreign currency. AML RightSource guided the institution down the path of obtaining the necessary registrations at the federal and state levels. AML RightSource also assisted the client in developing a robust BSA/AML program, written policies & procedures, and performed an internal risk assessment.
AML RightSource has been retained by a Private Equity Fund Administrator to assist in the design of a BSA/AML program sufficient to satisfy the FINRA 3310 regulation. AML RightSource also consulted in the development of a KYC, CIP and CDD Program to ensure that complete information was gathered during the investor on-boarding phase of the fund. Additionally, AML RightSource developed the appropriate BSA/AML policies & procedures that would be conducive to a Private Equity fund and consistent with the expectations of FINRA. Finally, AML RightSource provided OFAC consulting and with certain private equity funds, conducted the OFAC SDN, PEPs, and Section 311 Special Measures list screening and due diligence of potentially positive name matches.