BSA/AML Compliance
SERVICE OVERVIEW
Trust companies and bank trust departments manage unique risks, acting as fiduciaries for assets that may be used for layering or concealing illicit funds.
Our comprehensive BSA/AML compliance services are tailored to the distinct, non-traditional banking activities of trust companies and trust departments—including the administration of personal trust, investment management agency, custody and other accounts. We provide a tailored, specialized approach to creating risk-based, compliant AML programs and satisfying stringent AML legal and regulatory requirements.
Core Services
- Trust-Specific Risk Assessments: We perform AML risk assessments to assist our clients in identifying and mitigating money laundering, terrorist financing and other illicit risks related to trust and fiduciary activities. These risk-based assessments help our clients identify and mitigate possible internal control gaps and drive necessary changes in their AML compliance program. The AML risk assessment process allows us to consider and address specific risk categories (e.g., products, services, customers, and geographic locations) unique to each institution and whether they align with an institution's risk appetite.
- Tailored Policies, Procedures & Internal Controls: We work with our clients to verify that the their system of internal controls relative to AML compliance, is commensurate with their respective size, complexity and organizational structure. In so doing, we determine whether the institution's controls are appropriately aligned with the institution's risk appetite and will facilitate compliance with legal and regulatory requirements.
- Independent Audit & Testing: We are prepared to perform risk-based independent reviews (generally every 12–18 months) of client AML programs to determine whether their AML compliance programs are robust, compliant, and meet regulatory requirements and industry standards.
- Transaction Monitoring & Suspicious Activity Reporting (SAR): We are able to help clients create and implement manual or automated risk-based transaction monitoring processes to identify and address possible unusual account activity. We also create processes to escalate potential suspicious activity requiring further review and possible filing of Suspicious Activity Reports.
- Training for Fiduciary Personnel: We can create and/or deliver specialized, risk-based training to those whose roles and responsibilities require them to be familiar with AML compliance requirements, including the board of directors, senior management, trust officers, investment officers and other trust professionals. This training would help these professionals recognize red flags and suspicious activity and to escalate the same, consistent with the AML Program.
- Due Diligence for Fiduciary Accounts: We can develop and implement appropriate risk-based procedures for conducting customer due diligence throughout the client lifecycle.
- OFAC and Other Watchlist Compliance: We can help identify appropriate systems and processes to screen applicable parties against OFAC and other watchlists (FinCEN 314(a), politically exposed persons, etc.). We can also provide guidance on how to review and disposition potential matches, which may be authentic or represent false positive results.
Why Choose Our AML Compliance Services?
- Fiduciary Focus: We understand that trust risks differ from deposit-taking; our team specializes in identifying risks associated with high-secrecy structures.
- Regulatory Expertise: Deep understanding of AML laws and regulations and how they apply to trust companies and trust departments of banks.
- Preventive Approach: We help create processes to help you prevent, detect, and report suspicious activity, shielding your institution from reputation damage and heavy enforcement actions.
