Client:
Investment bank with retail client base

Engagement:
The client had instituted education and process changes to keep employees and procedures in compliance with Anti-Money Laundering (AML) regulations including USA PATRIOT ACT and other related requirements. We were asked to review the processes to ascertain that these measures were adequate and complete.

Deliverable:
After reviewing their AML procedures to ascertain appropriate controls, checks and balances, we interviewed staff responsible for or impacting the firm’s compliance with AML requirements. Once this information was gathered, we performed an analysis to determine any gaps and to identify the type and content of appropriate reference tools to support the staff’s continued compliance.
We made several procedural change and supervisory control recommendations to strengthen compliance and assisted the client in implementing these changes. Once these changes were in place, we designed reference tools in hard copy collateral form as well as system "clues", e.g., "Is this a reportable activity or situation?" and FAQ.

Result:
We observed staff performing various functions, including New Accounts and Stock Record, and evaluated their use of the new reference tools. It was determined that these new tools were helpful in reminding, directing and informing the staff of critical information and/or appropriate steps to take when confronted with a potential AML situation.

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