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:
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.