Anti-Money Laundering and Counter-Terrorist Financing Compliance
Promontory is an international leader in helping financial institutions enhance their anti-money laundering and anti-terrorist finance compliance, including compliance with the Bank Secrecy Act, the USA PATRIOT Act, and statutes administered by the Office of Foreign Assets Control (“OFAC”). Contact us to find out how we can help you.
Promontory offers services to help your institution both understand the requirements and enhance your compliance operations in practice, including the following:
Risk Assessments
Regulators require financial institutions to categorize customers, products, and businesses based on anti-money laundering compliance risks and develop programs to manage those risks. Promontory can work with your financial institution to develop risk categories, review your institution’s existing risk assessment programs, identify gaps in your compliance procedures, and recommend enhancements to close those gaps. Our assistance has helped institutions obtain positive examination results, avoid enforcement actions, and rectify compliance programs to obtain the lifting of enforcement orders.
Regulatory Communications
Promontory can assist your institution in communicating with regulators regarding the state of its anti-money laundering compliance and its planned enhancements.
Policies and Procedures
Most institutions need help logging, writing, and improving anti-money laundering policies and procedures. Promontory can identify deficiencies in existing policies and procedures and, if need be, write policies and procedures custom-tailored to your institution’s circumstances.
Forensic Analysis
Enforcement actions typically require banks to undertake a forensic analysis of past transactions for suspicious activity. Promontory’s professionals and forensic analysis systems combine judgment and technology to produce superior forensic results.
Testing
Financial institutions must conduct periodic independent testing of their anti-money laundering compliance programs. Promontory can perform this independent testing for your institution or, alternatively, develop an independent testing program for use by your institution’s independent audit program.
Training
Financial institutions are required to have anti-money laundering training programs. Promontory offers training programs specifically developed for (1) boards of directors, including audit committees of boards of directors; (2) foreign bankers operating in the United States; and (3) high risk business areas such as private banking, wire rooms, foreign correspondent banking operations, and other high risk areas.
Software Solutions
Through our affiliate, Promontory Compliance Solutions, we offer software that allows you to identify, quantify, and mitigate compliance risk, record and monitor audit issues, expected actions, and regulatory commitments, and assess geographic money laundering risk. Click here for more information.
Michael A. Dawson heads Promontory’s anti-money laundering practice. Contact us to learn how we can work with your financial institution.
