Financial Crime - the mode of making money illegally, and the subsequent money laundering activities - converting illegal money into what seems to be legitimately earned money, is a large and widespread problem. The United States Department of Treasury estimated in 2018 that domestic financial crime generates around $300 Billion that has a potential to be laundered. Crimes like fraud, drug trafficking, human trafficking, organized crime and corruption - which does not include tax evasion - generate the bulk of this estimated amount. Data from law enforcement and criminal investigations suggest that while money earned from financial crime tends to stay within the United States, we also are an attractive destination for illicit funds generated abroad.
When financial institutions knowingly or inadvertently allow financial crimes to take place, not only do they propagate criminal activity, once detected they can face large fines from the government.
A majority of the financial institutions strive to maintain checks and balances to -
- Know their customer
- Monitor and report suspicious activity
- Detect and prevent financial crimes
However, the dominant challenge has been a deluge of data and a large amount of "false positives" - innocent customers who appear suspicious - which allows the real criminals to slip by undetected. Government regulations require better controls to assess, manage and mitigate risks. And while financial institutions strive to stay compliant, it ends up being a trade-off between speed of doing business and the associated customer satisfaction score, and assuming the risk of financial crime going by undetected.
While larger institutions maintain a robust in-house compliance team that addresses their needs, it is not always a strategic advantage for small and mid-sized institutions to maintain their own in-house team of compliance experts.
And yet, the need to stay up-to-date with ever-changing regulations is a business imperative.
The APN Compliance Consulting, Inc. team has several years of deep domain expertise in consulting through -
- Thorough assessment of current level of compliance preparedness
- Risk exposure evaluation
- Remediation strategies to address highest to lowest risk areas
- Mitigation strategies to minimize future exposure and rework
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.
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.