Anti-Money Laundering

AML Program Redesign and Implementation

Whether as a result of an enforcement action or as a self-initiated project, Bates AML & Financial Crimes can work with financial institutions to evaluate, redesign and implement part or all of an AML program. Our experienced consultants can advise financial institutions on current industry standards and best practices in AML and Financial Crimes in the following areas: program governance, policies and procedures, BSA/AML/OFAC risk assessments, name screening, KYC transaction monitoring, and case management systems and processes, customer risk scoring models, staffing capacity plans, systems integration and implementation, and transaction monitoring system tuning and optimization.


Financial Institutions are required to conduct independent audits of their AML programs. In order to achieve complete independence and also to benchmark a financial institution’s AML program against industry best practices, it is important to use a third-party consulting firm for your annual audit. Bates has experienced AML auditors who can help AML departments in this critical area.

Backlog, Lookback and Key Person Staffing Support

Bates AML & Financial Crimes provides experienced staffing to financial institutions to assist in the clearance of backlogs or to conduct lookbacks in the following areas: customer due diligence (CDD) reviews, enhanced due diligence (EDD) reviews, name screening alerts, OFAC alerts, 314(a) alerts, transaction monitoring alerts, case investigations and suspicious activity reports (SAR), trade surveillance alerts, and fraud alerts.

Bates also provides their clients with “key person” staffing. Our experienced consultants can stand in to cover key positions in AML and Financial Crimes departments on an interim basis.

Customer Risk Scoring Model Design, Testing, Tuning, and Implementation

It is critical to evaluate the AML risk that each customer represents to the financial institution. Bates can evaluate your current state risk scoring model and advise how to enhance their customer risk scoring. Alternatively, we can design entirely new risk scoring models that are tailored to your AML program. We will work with you to test, tune and implement the risk scoring model.

Gap Assessments

Whether due to regulatory intervention or as a self-initiated project, Bates 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 current industry AML standards and best practices. 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.

KYC System Design, Testing, and Implementation

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. The Bates 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.

Regulatory Response

Bates 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.

Risk Assessments

An integral component of a robust BSA/AML Compliance program is the completion of an annual BSA/AML/OFAC risk assessment. Financial institutions should conduct tailored 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 has experienced consultants who specialize in risk assessments from the smallest to the largest and most complex financial institutions.

Transaction Monitoring Business As Usual Investigations

Bates 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.

Transaction Monitoring Look-Back Investigations

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 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).

Transaction Monitoring Model Tuning and Optimization

Regulators expect financial institutions to tune their AML transaction monitoring models annually. There continues to be a high level of regulatory scrutiny in this space. Bates can perform the tuning and optimization of your transaction monitoring models with AI and machine learning or via or non-AI/ML tuning methods to ensure that it meets the expectations of your regulators.

Transaction Monitoring Model Validation

It is a regulatory expectation that model validations are performed on a financial institution’s AML transaction monitoring model by an independent third party. The model validation evaluates the conceptual soundness of the model, governance, data flows, coverage, tuning and optimization, and model output in an end-to-end evaluation. Bates can perform your model validation as an independent third party.

Bank Secrecy Act

The Bates AML & Financial Crimes team of expert professionals and consultants provides a comprehensive set of services and continuing guidance tailored to the needs and requirements of our financial services industry clients. Our expert team of Anti-Money Laundering (AML) professionals are well versed in the Bank Secrecy Act, the primary U.S. AML law, and can assist in the monitoring and reporting of BSA compliance. Click here to find a BSA expert.

Other AML Services

Bates also offers services to support:

  • Cryptocurrencies
  • Governance of AML Program
  • AML and Fraud Investigations
  • Litigation Support and Expert Testimony
  • Marijuana and Cannabis
  • Name Screening Systems
  • Policies and Procedures
  • Systems Integration and Implementation.

Examples of Bates Group‘s Capabilities

Anti-Money Laundering

  • Bates provided a team of AML investigators, together with a project manager possessing specific and related experience, to assist a large client with a regulatory inquiry regarding thousands of negative news, free look and fraud transactions going back three years to determine if SARs should have been filed or if the matters were appropriately closed. We helped the client quickly assess the potential scope of matters in which SARs should have been filed, but were not.
  • Bates assembled a team of AML investigators and project managers to help our client catch up on a large number of business as usual transactions in order to eliminate their backlog of matters and ensure the timely filing of SAR reports. Bates Group’s experienced AML investigators were able to quickly review the backlog of negative news, fraud and other transactions, assist with 314(b) requests, and draft SARs when appropriate.
  • Bates put together a team of AML investigators when its client determined that an AML rule was incorrectly applied. Our experienced team was able to quickly review all matters within the time period in question, investigate specific transactions, perform continuing activity reviews, draft SARs where appropriate, and close the matters.

Contact Bates Group

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

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