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Anti-Money Laundering Compliance



Solving the Anti-Money Laundering Compliance Problems

AML compliance challenges of covered financial institutions requires more than familiarity with relevant laws and regulations. Effectively addressing money laundering and terror financing compliance requires real-world experience with the underlying criminal activities that lead to money laundering, an ability to foresee opportunities that money launderers see, in-depth knowledge of investigative methods, and a honed understanding of regulatory expectations.

Effective AML Programs integrate the entire hierarchy of a financial institution, from the Board of Directors who are ultimately held accountable for non-compliance, to all of the firm’s relevant employees responsible for identifying unusual activities indicative of possible money laundering. Accordingly, AML Programs benefit greatly from insight gained through successful experiences as the designated AML Officer or person accountable for BSA compliance at one or more financial institutions.

FE&E, Inc’s personnel are prepared to meet these challenges, having extensive experience in what world well and what does not work at all.

FE&E, Inc’s AML Compliance Practice Group provides services in each of the following critical AML program areas:

  • Independent testing of AML programs where there is a concern regarding regulatory action, and help when regulatory action has taken place.
  • If you have a basis for questioning whether your AML program will meet regulatory expectations — you have had a prior regulatory finding, you have acquired a new business or added new services, or you now face additional BSA regulatory requirements — you want the outside evaluation performed by someone with the experience to recognize and rectify the problem before a formal action, up to a Cease and Desist Order, is issued.
  • Our highly experienced staff is equipped to perform an independent test that has an exemplary degree of reliability for firms and their regulators. This minimizes the likelihood of having to pay for expensive after-the-fact remediation of program deficiencies.
  • AML/BSA Remediation: KYC, “CIP”, EDD, Look-backs and Remediation of Policies, Procedures and Operational Processes
  • Development and Implementation of firm-level of risk assessment protocols for AML/BSA or Sanctions Compliance
  • Mentoring designated AML Compliance Officers or Committees of financial institutions, especially working with foreign financial institutions with branches or operations in the United States
  • Developing risk-based Customer Identification Programs including Customer Due Diligence and Enhanced DueDiligence Processes for high-risk international issues
  • Assessment and Review of Suspicious Activity Reporting (SAR) Processes employed by client firms
  • Anti-money laundering and Sanctions compliance training tailored to senior staff and the financial institutions’ Board of Directors




A retainer client called with a problem, a man was depositing anywhere from $800,000 to $1,200,000 per week in cash. All bank employees were certain this was money laundering. She was not so it was money laundering certain as there was no effort to conceal anything. A quick investigation of the clients business found that the business was highly regulated and highly taxed and that 60% of every dollar that came through the door had to be paid to the state same if collected before 3 pm and next day if collated afterwards. The business could literally not afford 3 day holds on checks, wires that could be recalled, etc… thus it was cash. Learning of the malady of the business the banker was able to set up cash in transit services as well as deploy some additional assistance to the clients and the customers. Once the mechanisms were in place the banker recruiters others in the same business and increased the average daily collected balance for the bank by 17 million dollars.