Performed end-to-end review of the client’s overall AML program against industry best practices, identified key gaps and offered recommended program changes. Areas of review included:
- Client vetting and on-boarding documentation
- Risk rating methodology
- Surveillance monitoring program including research, escalation and SAR filing
- Alignment of processes with regulatory requirements, industry standards, and documented procedures
- Effectiveness of implemented compliance-related technology
- Data quality and consistency
- User training
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