Anti-Money Laundering – AML Compliance Program

Anti-money laundering (AML) programs are required for financial institutions, money services businesses, investment firms, and other organizations that may process large cash (or cash equivalent) transactions. Cendrowski Corporate Advisors is frequently engaged by these organizations to assist with the evaluation and development of AML processes.

AML Compliance Programs

Our seasoned team of AML specialists assists organizations with the development, evaluation, and improvement of AML compliance programs, including:

  • Common improvements include updating the program for new requirements (i.e., beneficial ownership detection), updating and augmenting written documentation, and development of staff training programs
  • Regulatory examination to provide a dry run of the inspection to identify defects in the design and make recommendations for improvement
  • Assistance to financial institutions under FDIC memorandum of understanding to resolve AML compliance issues

The Bank Secrecy Act (BSA) and its implementing regulations, most notably the USA PATRIOT Act, defines rules to help detect and report suspicious activities that may be money laundering indicators. Other regulatory organizations, such as the FDIC, NCUA, and FINRA, have also implemented their own rules and guidelines for compliance with the regulations.

Client Success: Regional Bank Review

Cendrowski Corporate Advisors was engaged by a regional bank to perform a comprehensive review of their anti-money laundering procedures, including customer due diligence programs, customer procedures, AML training programs, and current staff capabilities.

Additionally, our AML specialists performed a look-back review of all accounts and transactions flagged by the bank’s AML monitoring system to evaluate the bank’s capabilities to detect and report potential money laundering in accordance with all applicable BSA reporting requirements. Our team’s work product was favorably received by the FDIC.

BSA and AML Lookbacks for Banks and Credit Unions

Cendrowski Corporate Advisors frequently works with banks and credit unions to help them assess and implement procedures related to their Bank Secrecy Act (“BSA”) Compliance Programs. Our team members have handled money laundering cases locally and nationally and monitored fraud activity for large banks and credit unions. In many situations, we have assisted the bank while they were under FDIC scrutiny.

Our dedicated and experienced anti money laundering team will review, assess and develop the bank’s written program for monitoring and reporting suspicious activity to comply with all applicable requirements of the FDIC’s Rules. We also provide training for the bank board of directors, management, staff, and BSA Staff regarding their responsibilities for identifying and reporting suspicious activity, including filing Suspicious Activity Reports (SAR).

As an independent and qualified third party, Cendrowski Corporate Advisors can:

  • Perform lookback reviews of deposit accounts and transaction activity to ensure that all suspicious activity involving any customer accounts of, or transactions through, the bank were properly identified and reported in accordance with all applicable BSA reporting requirements
  • Consult on BSA Risk Assessment procedures to include all risk areas, including any new products, services, targeted customers, entities, and geographic locations
  • Assist banks with the development and implementation of a written Customer Due Diligence (CDD) Program. The program requires a risk-focused assessment of the customer base to determine the appropriate level of ongoing monitoring necessary to ensure that the bank can reasonably detect suspicious activity
  • Conduct enhanced customer due diligence (ECDD), performing extensive background and relationship investigations, including in-person interviews, when needed, to document the underlying business arrangements of the customer

Know Your Customer Programs

Know Your Customer programs (KYC) help organizations verify their customers’ identities and assess their risk to the organization. These business verification programs require the organization to understand fine details about the account holder, including the nature of their business, source of income, and business relationships.

  • As the organization processes cash transactions for the account holder, the transaction must be evaluated against the understanding of the business to identify suspicious activity
  • KYC risk assessment processes must be ongoing, not a one-time evaluation, and need to involve different areas of the organization to be comprehensive
  • Training is essential, so people across the organization understand their role in the KYC/AML compliance program

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