Enforcement Action Response

Challenge Client receives MOU requiring substantial changes to AML program

Worked closely with senior client team to address each item cited in the MOU, including:

  •   Enhancing transaction surveillance process with implementation of new rules
  • Evaluation and selection of a new transaction monitoring system
  • Implementing a 3-year lookback transaction review for their corporate and correspondent banking unit, and providing a full team of researchers to staff the lookback team
  • Developing and deploying a customer risk scoring model