Bates Group has successfully assisted a number of financial institutions in connection with AML regulatory-related inquiries and responses. Our success in helping our clients is due in large part to the experience and insight of our CAMS-certified consultants and AML project managers, many having previously worked for regulatory agencies and also have been members of AML teams working on behalf of some of the largest financial institutions in the United States. Their collective and unique insights, coupled with their industry knowledge and regulatory know-how, help our clients meet regulatory expectations and resolve AML deficiencies in the face of regulatory scrutiny.
The cornerstone of a strong BSA/AML Compliance program is the implementation of comprehensive policies and procedures that enable financial institutions to determine their clients’ risk for money laundering, financial crime and or terrorist financing activities. Bates Group’s team of experts and consultants have many years of experience working in regulatory environments as inside and outside counsel and as Compliance professionals for some of the world’s largest financial institutions. These experts and consultants can help implement, review and test each client’s Customer Identification Program (CIP) and Know Your Customer (KYC) program including policies and procedures, KYC customer risk scoring models, Customer Due Diligence (CDD), Enhanced Due Diligence (EDD) and Beneficial Ownership requirements as required by the FinCEN Customer Due Diligence Rule.
Whether due to regulatory intervention or self-initiated assessment, a look-back review of clients and transactions may be necessary to address potential concerns regarding transaction activity. Within days, Bates Group can and has placed a significant number of AML investigators, together with AML project managers, at our financial institution clients to assist with AML investigations involving negative news, fraud, regulatory subpoenas, reviews of transaction monitoring alerts and case investigations. Our experienced AML investigators understand the intricacies of a look-back review while gaining information to clear alerts, assisting with 314(b) requests, producing case investigation narratives supported by evidentiary documentation and, if necessary, ultimately drafting and filing Suspicious Activity Reports (SARs).
Bates Group also places AML investigators and project managers at our financial institution clients within days to assist with BAU reviews and AML investigations involving negative news, fraud, regulatory subpoenas, transaction monitoring and case investigations in order to reduce or eliminate backlogs. Our experienced investigators assist with all aspects of the investigation, including reviewing transaction monitoring alerts, assisting with 314(b) requests, producing an investigation narrative supported by evidentiary documentation and ultimately drafting and filing Suspicious Activity Reports (SARs), when necessary.
It is a regulatory expectation that financial institutions test and tune their AML transaction monitoring systems annually, and there continues to be a high level of regulatory scrutiny in this space. Bates Group’s team of experienced consultants will work with your financial institution to evaluate the current state of your transaction monitoring system to ensure that it is tuned to the expectations of regulators.
An integral component of a robust BSA/AML Compliance program is the completion of an annual risk assessment. Financial institutions conduct enterprise-wide risk assessments to evaluate the inherent risk of the various businesses at their firm against their control environment. Once residual risks are identified it is important for AML Compliance departments to enhance their AML programs to address the risk. Bates Group has experienced consultants who have conducted risk assessments at small- and medium-sized institutions, as well as at some of the largest financial institutions in the United States. These consultants are able to conduct a risk assessment tailored to your firm.
Whether due to regulatory intervention or as a self-initiated project, Bates Group can assess and evaluate your AML Compliance program to check whether it meets industry best practices. It is important to periodically conduct gap assessments in order to keep up with the current industry AML standards. Our consultants have considerable experience, knowledge of industry standards and expertise in all areas of AML Compliance, and are well-equipped to complete a gap assessment for your firm.
Examples of Bates Group‘s Capabilities
Bates Group sent a team of AML investigators to assist a client with a regulatory inquiry regarding thousands negative news, free look and fraud transactions going back three years to determine if a SAR should have been filed or if the case was closed appropriately. We helped the client quickly assess the potential scope of cases that should have, but did not have a SAR filed.
Bates Group sent a team of AML investigators to assist a client with a large number of business as usual transactions in order to help the client eliminate their backlog of cases and ensure timely filing of SARs reports when needed. Bates Group’s experienced AML investigators were able to quickly review the backlog of negative news, fraud and other transactions, file 314b requests, and draft SARs when appropriate.
Bates Group is with you every step of the way. Contact us today for more information on how our End-to-End Solutions can help your firm.Contact Bates Group