Our client was a Wholesale Operations business unit within a large bank. This unit had operationalized Anti Money laundering compliance program for 52 lines of business to comply with. These lines of business were in geographically diverse locations within east, mid west and west coast of United States of America with a 1.6 Trillion plus client base
Assess the adequacy of the bank’s AML program. Determine whether the bank had developed, administered and maintained an effective program for adherence to the regulations. The client engaged Bonova Advisory to provide an independent assessment on current state of this program since a lot of processes were undefined, roles and responsibilities were not clearly defined and clear accountability wasn’t established to manage the complexity of the regulation.
How we assisted the client:
The team at Bonova Advisory reviewed the current processes, policies and procedures. The team rapidly identified the risks and worked with key stakeholders from 52 lines of business to address the current challenges being faced in the compliance program. Current framework was assessed across the organization (legal, regulatory affairs, compliance,
Audit management and operational functions) to derive the effectiveness of the timeliness and accuracy of implementations related to regulatory changes. A self-rating matrix was designed to provide rating on processes driving the centralization, Standardization, accountability and consistency required for measurable transparency and visibility into operational compliance workflow. Over the course of 6 months engagement the team examined the AML compliance program for minimum requirements such as
- Establishment of a system of internal controls to ensure ongoing compliance
- Various checks such as 3 eye check established for SAR reports
- A review of bank’s risk assessment to align with bank’s risk profile considering products, services, customers, geographic locations and counterparties.
- Ongoing training for employees involved in AML compliance and audit of management actions/efforts in management of violations and supervisory actions.
The frequency of independent assessments/audits was also recorded to identify the monitoring and tracking of effectiveness of this compliance program.
The team at Bonova Advisory helped the client to audit the scope, effectiveness and maturity of the existing AML compliance program with the bank. The bank to uncover various gaps that existed between the current process and the best practices that should be implemented for the future roadmap then used our independent assessment/Audit findings. It assisted the bank in raising awareness of employing robust controls, framework and governance to consistently have an effective compliance program for complete adherence to the regulation.
An objective gap analysis produced results to identify the areas of improvement that bank needed to take action for meeting their current risk appetite and tolerance. This ultimately resulted in identifying and accurately measuring risk across products, services, customers and geographical locations. In addition to that the bank was able to raise their maturity level by pivoting their strategy in putting more efforts to build clearly defined policies and procedures, accountability and rightly trained staff. Navigating the challenges and complexities around AML compliance requires well-organised and structured oversight and review channels that examine the program as well as the surrounding governance, resourcing and ongoing maintenance controls that support the program. Our forensics team established most important requirements that needed to be assessed at regular intervals of 12-18 months for sound practices within AML program.
- Regular internal review and reporting to senior management and the Board
- Review processes for responding to changes that impact the risk assessment and the program
- Testing the performance of systems and controls
- A regular, robust and comprehensive independent review