BSA/AML Risk Assessment

Engagement Period: 2 months

Background

The client, a Foreign Banking Organization ("FBO"), was seeking a service provider to assist with a comprehensive review of the following, as a result of a Regulatory Matter:

• The review of its BSA/AML & OFAC risk assessment methodology against industry standards and certain regulatory expectations, and provide practical enhancement recommendations to address any gaps identified

• The review of its BSA/AML & OFAC risk rating calculation model against industry standards and regulatory expectations, and provide practical enhancement recommendations to address any

gaps identified; and

• To assist with the development of a roadmap to implement applicable enhancements required.

Approach

NextAML quickly deployed subject matter specialists with the appropriate technical skills and practical experience in commercial banking and an effective BSA/AML & OFAC Compliance Program. Our specialists are well-versed in regulatory requirements for FBOs, as well as industry standards, and included bi-lingual professionals who can interact and collaborate closely with Home Office and U.S. local management.

The review was performed using our proven risk assessment framework. This included using key matrices used in BSA/AML and OFAC risk assessments as well as reviewing and validating the customer risk rating methodology to ensure they are designed and performing in a manner that meets our understanding of regulatory expectations. Our professionals also leveraged their in-depth knowledge and skills to review every detail of the risk assessment methodology and results and provided practical and sustainable solutions to enhance the FBO's existing processes and controls.

Outcome

The client successfully completed the risk assessment review and implemented the identified enhancements working with Head Office, in line with the remediation timeline; and the remediation effort was successfully validated by Internal Audit.