Anti-Money Laundering (AML) Program

Whether as a result of an enforcement action or as a self-initiated project, Bates works with financial institutions to evaluate, redesign and implement part or all of an AML program. Our experienced consultants can advise financial institutions on current industry standards and best practices in AML and Financial Crimes in the following areas: program governance, policies and procedures, BSA/AML/OFAC risk and gap assessments, audits, KYC and customer risk scoring, and systems integration and implementation

Financial Institutions are required to conduct independent audits of their AML programs. In order to achieve complete independence and also to benchmark a financial institution’s AML program against industry best practices, it is important to use a third-party consulting firm for your annual audit. Bates has experienced AML auditors who can help AML departments in this critical area.

Bates provides assistance to financial institutions in the clearance of backlogs or to conduct lookbacks in the following areas: customer due diligence (CDD) reviews, enhanced due diligence (EDD) reviews, name screening alerts, OFAC alerts, 314(a) alerts, transaction monitoring alerts, case investigations and suspicious activity reports (SAR), trade surveillance alerts, and fraud alerts.

It is critical to evaluate the AML risk that each customer represents to the financial institution. Bates can evaluate your current risk scoring model and advise how to enhance your customer risk scoring. Alternatively, we can design new risk scoring models that are tailored to your AML program.

Whether due to regulatory intervention or as a self-initiated project, Bates can assess and evaluate your AML Compliance program to check whether it meets industry best practices. It is important to periodically conduct gap assessments in order to keep up with current industry AML standards and best practices. Our consultants have considerable experience, knowledge of industry standards and expertise in all areas of AML Compliance, and are well-equipped to complete a gap assessment for your firm.

The cornerstone of a strong BSA/AML Compliance program is the implementation of comprehensive policies and procedures that enable financial institutions to determine their clients’ risk for money laundering, financial crime and or terrorist financing activities. The Bates team of experts and consultants have many years of experience working in regulatory environments as inside and outside counsel and as Compliance professionals for some of the world’s largest financial institutions. These experts and consultants can help implement, review and test each client’s Customer Identification Program (CIP) and Know Your Customer (KYC) program including policies and procedures, KYC customer risk scoring models, Customer Due Diligence (CDD), Enhanced Due Diligence (EDD) and Beneficial Ownership requirements as required by the FinCEN Customer Due Diligence Rule.

Bates has successfully assisted a number of financial institutions in connection with AML regulatory-related inquiries and responses. Our success in helping our clients is due in large part to the experience and insight of our CAMS-certified consultants and AML project managers, many having previously worked for regulatory agencies and also have been members of AML teams working on behalf of some of the largest financial institutions in the United States. Their collective and unique insights, coupled with their industry knowledge and regulatory know-how, help our clients meet regulatory expectations and resolve AML deficiencies in the face of regulatory scrutiny.

An integral component of a robust BSA/AML Compliance program is the completion of an annual BSA/AML/OFAC risk assessment. Financial institutions should conduct tailored enterprise-wide risk assessments to evaluate the inherent risk of the various businesses at their firm against their control environment. Once residual risks are identified it is important for AML Compliance departments to enhance their AML programs to address the risk.  Bates has experienced consultants who specialize in risk assessments from the smallest to the largest and most complex financial institutions.