The Bank Secrecy Act (BSA) was passed by Congress in 1970 and brought into effect the Anti-Money Laundering (AML) law. It mandates a host of institutions to detect and prevent money laundering. The FinCEN or Financial Crimes Enforcement Network is the enforcer of BSA and includes parts of the USA Patriot Act Compliance that focuses on money laundering as a form of terrorist funding.

Important areas of focus for organizations are –

  • Transaction look-back
  • KYC remediation
  • Threshold testing and tuning
  • Trade surveillance
  • Data management
  • End to end case management
  • Suspicious activity reporting

Organizations required to comply with the BSA laws are Depository Institutions, Money Services Businesses, Mortgage Companies/Brokers, Securities/Futures, Casinos, Insurance Agencies, and Precious Metals/Jewelry stores.

Today, several tools and technologies are available that address this important compliance area.  However, organizations are constantly challenged with maintaining a balance between ensuring that they stay vigilant and compliant and running their business effectively by not “over-screening” their customers.

Organizations can effectively manage risk and compliance through Modeling & Analytics, Data Services, Automation (RPA), Quality Assurance, and Managed Services. 

APN Compliance Services

APN’s Compliance Division provides AML compliance advisory, consulting, and IT services.  Our delivery teams have deep experience in all aspects of financial compliance.  We have developed expertise on the business side as well as technology that supports the AML compliance needs. 

 

We can offer services customized to your unique needs based on current business scenarios and organization goals.   Based on business criticality, regulatory requirements, and business goals, we can design an engagement model that addresses areas that require immediate attention while preparing your organization for accelerating business results while mitigating risks.  Following is a list of the major services offered by APN Compliance Consulting.

 

  • Compliance Audit Services - Organizations differ in their business processes and carry their own set of unique challenges in instituting proper controls and governance.  APN audit services offer a thorough assessment of current levels of compliance preparedness and provide recommendations for an ideal future state.  While an organization may be up to date on their compliance readiness, it does not guarantee a lapse in the future that may be caused as a result of ever-changing business landscape and regulatory mandates.  APN’s Advisory Services offers strategies designed by foremost subject matter experts who offer thought leadership on developing a fortified compliance program that addresses external as well as internal operational risks.
  • Compliance Program Remediation - Based on findings of the audit exercise, APN Compliance Program Remediation services can deploy experienced resources that can lay out a sound plan and execute steps to remediate gaps in your compliance
  • Technology Consulting Services - With transactions becoming ever-increasingly paperless, cyber-crime is on the rise.  This has forced compliance technology companies to constantly keep up their efforts in creating counter measures by introducing new features.  New applications that are best suited to an organization’s needs come up, but an organization may be committed to their current platform.  APN Technology Consulting Services team provides an agnostic view of the many choices offered in the market and helps you evaluate cost-benefit analyses of an optimal solution. Customer and transaction data are being collected at an exponential rate.  With new data arriving every day, it is critical to be able to monitor transactions, trends, suspicious activity, and even glean insights on potential business opportunities.  APN offers data analytics services to help you derive rich benefits from your data.  Our teams can work with any amounts of disparate data sets to build optimal data lakes, develop user stories, and provide data backed strategies to improve business outcomes.
  • Risk Assessments - Within our Advisory Services we can provide risk assessment services that gives you a holistic view of your highest to lowest risk areas and provide mitigation strategies to minimize future exposure and rework.  We can provide you with a Risk Calculation Score and Risk & Controls Matrix to better manage your risk profile.
  • Model Validation - It is a mandate to validate your model framework for effectiveness and currency.  While your stakeholders are focused on key business activities, APN’s teams can help ensure that the controls you have in place are adequate.  Our validation services are compliant with industry standards NY DFS 504, OCC 2011-12 and SR 11-7.
  • Lookback - On occasion, government regulations mandate a look-back into past transactions for proactive risk mitigation.  APN’s teams can help you efficiently perform a comprehensive look-back and provide a clean report of findings.
  • SAR - The most ideal situation would be when you can monitor your customer transactions real time, affect timely intervention to assess risks and take proactive measures to mitigate the real threats.  APN can provide a dedicated team to monitor suspicious activity, investigate transactions for false positives, and effectively filter clean transactions without letting the real miscreants slip by.  We assist with SAR filing, lookback transactions, and threshold testing and tuning. 
  • Customer Due Diligence / Enhanced Due Diligence - While business imperative is to add as many new customers as possible, new customer due diligence, and existing customer enhanced due diligence due to suspicious activity can slow down the pace of growth.  APN can become an extension of your internal stakeholders and assist you in streamlining your customer due diligence process so you can focus on growing your business.
  • AML Rules Tuning - Business rules that govern detection of suspicious activity can quickly become outdated with new external factors affecting the current detection scenarios.  The timing of tuning your detection scenarios is of paramount importance.  APN can fine tune your current detection scenarios as well as lay out a plan to monitor and proactively strengthen your rules engine on an ongoing basis.

Talent Augmentation

For your existing projects, APN can also help you find the best talent in these areas.  Through our niche and focused compliance practice area and knowledge of Nice Actimize, Oracle Mantas, and other software, we can provide you with –

  • AML Administrator (SAS)
  • AML Business Analyst
  • AML Risk and Supervision Lead
  • AML IT Audit Consultant
  • IT Audit Manager
  • AML Compliance Manager
  • Director, AML Technology
  • AML/KYC Risk & Compliance Consultant
  • AML/Compliance Validation Consultant
  • AML Investigator
  • AML Solutions Architect
  • AML Program Manager

We are building a strong, nationwide network of this talent pipeline and can help you support your immediate needs.  Talk to one of our experts on how we may help you staff your positions with confidence.

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