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Rebuilding AML Compliance in Response to Regulatory Scrutiny

Rebuilding AML Compliance in Response to Regulatory Scrutiny

Facing an imminent Consent Order, a large retail bank operating across 10 states needed to overhaul its anti-money laundering (AML) compliance program. We were engaged to design and staff a new Financial Intelligence Unit (FIU), implement compliance enhancements and ensure regulatory expectations were met, leading to a best-in-class AML program that led to the lifting of enforcement actions. 

Challenge

With over 500 branches and a vast customer base, our banking client’s AML program was under severe scrutiny. Regulators were preparing to issue a Consent Order, which would have required extensive remediation, including increasing staffing levels, upgrading transaction monitoring systems, and overhauling policies and procedures. The bank lacked the internal resources and expertise to execute these changes efficiently while continuing to meet day-to-day compliance obligations. Leadership needed a partner who could not only bring the program up to standard but also ensure long-term sustainability and regulatory confidence.  

Solution

Dominion Advisory Group—now part of SolomonEdwards—was engaged to lead the transformation, providing strategic guidance and hands-on execution. The engagement included the following key activities:  

  • FIU development and staffing: Stood up a fully functional Financial Intelligence Unit (FIU), recruiting and onboarding dozens of analysts and investigators.  
  • Training and quality control: Conducted one-on-one training for each FIU team member and built a dedicated quality control function to ensure every alert and case investigation met regulatory standards.  
  • Technology and data analytics: Tuned and tested the bank’s transaction monitoring system, developed new models for identifying suspicious activity and conducted comprehensive risk assessments.  
  • Policy and governance: Drafted and implemented AML policies and procedures aligned with evolving regulatory expectations, providing executive and board-level guidance on compliance strategy.  
  • Regulatory reporting: Advised management and the Board of Directors on meeting monthly reporting requirements and ensuring transparency with regulatory agencies.  

 

Outcome

Through this structured and methodical approach, the bank successfully addressed all enforcement action components, leading to the eventual lifting of the Consent Order. Our client’s proactive compliance efforts, assisted by our expert-led remediation efforts, turned a potentially troublesome situation around; moreover, the newly built AML program became a model of compliance excellence, recognized by regulators as one of the strongest in the industry.  

  

Dominion Advisory Group, now part of SolomonEdwards, brings specialized expertise in anti-money laundering (AML) advisory and financial crime consulting. Learn more about our services in the Banking & Financial Services industry.   

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