Anti-Money Laundering (AML) & Risk Management
Due to our broad range of experience in governance and risk management at Fortune 500 companies, our teams are well equipped to handle even the largest AML/CFT projects. For large firms, we provide solid staff augmentation services. We have observed, however, that smaller institutions are often underserved, and have some unique challenges. We are also pleased to serve the mid-sized financial sector – including credit unions and regional banks – and look forward to helping your firm stay fully compliant with the regulations governing your operations.
Complex and ever changing regulations along with increased attention from regulators exposes institutions to both financial and reputational risk. Solid, well documented risk modeling is required to produce AML/CFT programs that are effective and satisfy the regulatory agencies.
Our Advisory Services Encompass Five Broad Areas:
|Audit Risk Assessment||AML/CFT Solution Implementation||Front Office Staff Training|
|Pre-Risking / De-Risking||Crisis Mitigation|
Summary of Services:
Recent FATF and FinCEN guidance indicates that financial institutions should apply a Risk Based Approach (RBA) to their Anti-Money Laundering / Countering the Financing of Terrorism (AML/CFT) programs. The foundation of this approach suggests that internal auditors develop Audit Risk Assessment tools specific to their organizations, and that these tools are periodically updated. The recommendation is that an AML Risk Assessment be conducted annually. Enterprise Iron consultants can help your staff construct or tune your AMLRA tools, assist in the annual audits, or can conduct a full independent audit.
Once Risk models are developed, they need to be turned into controls, and require software systems and processes & procedures to implement those controls. Our consultants have experience with multiple systems, and can assist in the installation, upgrading, or configuration of the software you use. In addition, as a firm we have long specialized in the interface between the business and IT sides of the house. In the case of AML/CFT, this means understanding how to construct the processes and procedures your compliance staff will use to interact with the software so as to align business processes with the risk profiles articulated in the Risk Assessment.
While internal auditors and compliance staff have a relatively sophisticated understanding of AML/CFT requirements and processes, the client-facing staff also have an important part to play Periodic training is critical especially when internal systems or processes, or regulations have changed. Our people are expert at producing the sorts of materials that non-specialists can understand, and are able to run the training courses required to keep your front office staff up to date.
Pre-risking (choosing not to enter lines of business or business sectors), and especially De-risking (closing accounts in lines of business or business sectors) are becoming widespread. When done incorrectly, it upsets regulators, and exposes you to reputational risk. Getting it right requires experience, and our consultants have the skills to help you walk that fine line.
Regulatory audits do happen, and they do not always result in the best outcomes. Non-compliant firms often need to bring in independent firms to correct identified flaws in processes and procedures, software, or staff training. Our Crisis Mitigation teams review the audit, construct a roadmap from the current state to full compliance, and bring in the specialists required get the job done. Emphasis is placed on moving carefully, but quickly.