Transaction monitoring, whether as a result of a regulatory inquiry or as part of a self-imposed lookback due to a backlog of alerts, can create an immense strain on the resources of financial institutions such as retail banks, investment banks, financial services firms, and virtual currency exchanges.
Historical Transaction Lookbacks
Our dedicated team of Anti-Money Laundering (AML) specialists will work with you to navigate the through challenges of a historical transaction lookback from data acquisition to regulatory filings. We are practical team players, focused on helping our clients develop and maintain an efficient and fully compliant transaction monitoring historical review.
Understanding that no two financial institutions are the same, we have a bespoke approach to each engagement that takes into account the institution’s resources and its current compliance program, as well as its prior history with regulatory inquiries. Based on our initial assessment, we implement a multipronged approach using our proprietary case management system that allows our clients to securely share data source information subject to the scope and timeline of the review.
- Data Acquisition and Analysis: We assist with the identification of all sources of transactions related to the population under review and will work with system owners to extract and analyze data feeds and perform a data quality analysis.
- Scenario Development: We analyze the transaction profile to determine the scenarios and parameter values to be implemented in the transaction analysis. Based on this information, we build customized scenario logic to meet our client’s risk assessment transaction profile, perform a threshold analysis to determine appropriate monitoring levels, and analyze test alerts to assess the thresholds.
- Generation of Alerts and Development of Procedures: We prepare the production environment and generate alerts based on the migration of all test data, customer and transaction data, and scenario code. As a part of this preparation, we develop tailored procedures and conduct training for all staff assigned to the transaction review.
- Multilevel Review: Our three-level review process for the case lifecycle ensures that each alert is thoroughly vetted and properly routed. The process begins with a dedicated team of analysts that conduct due diligence research on the appropriate parties and prepare a memorandum of information, followed by team leader review to assess whether the case should proceed to the quality assurance team, and bookended with the quality assurance review, which uses a flexible process to review the analysts’ work on a risk-responsive basis for ultimate disposition under the direction of the client’s Bank Secrecy Act (BSA) officer.
- Suspicious Activity Report Review and Drafting: In cases where our client agrees that a suspicious activity report (SAR) filing is warranted, we provide two teams to handle the process. Our specialized team of SARs preparers drafts the SAR narrative and our SAR reviewers verify the information and ensure that the narrative is clear, concise, and accurate. We complete each SAR in accordance with Financial Crimes Enforcement Network (FinCEN) requirements and will promote the completed SAR form to the institution for final submission to FinCEN.
Transaction Alert Backlog
We also assist with clearing a backlog of business-as-usual (BAU) alerts for financial institutions experiencing an unusually high volume of monthly alerts or an untimely attrition of staff. Because of our flexible approach, we can adapt our traditional lookback model for the purpose of a backlog, utilizing our client’s existing protocols or developing a blended approach. Depending on the client’s needs, we can offer co-sourcing or staff augmentation options for alert clearing or SAR drafting for short- or long-term projects. We have analysts who are trained in surveillance, list screening, and due diligence tools. Our senior practitioners have in-depth experience with the full range of transaction monitoring systems, such as Actimize, Norkom, Mantas, FCRM, and Prime. With the ability to work remotely or at our client’s site, our teams are available on a global basis to meet the needs of our clients’ global businesses.
