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Our client’s failure to identify and report suspicious domestic and international wire activity put it at risk of severe regulatory action. Gaps in its FIU’s organizational structure, transaction monitoring and case management processes meant that potentially illicit financial activities were going undetected. Regulators demanded swift and effective remediation, and bank leadership needed a clear plan—along with the right expertise—to execute it successfully.
Dominion Advisory Group—now part of SolomonEdwards—was retained to conduct a comprehensive evaluation of the FIU’s structure, operations and effectiveness. Our team examined:
We then developed a corrective action plan, which provided clear recommendations with defined timelines, resource requirements and implementation strategies. At the request of the bank’s executive management and board of directors, we stayed on to lead the implementation of the plan.
Over a six-week period, we were able to help the bank rapidly address and remediate regulatory concerns, focusing on strengthening the FIU’s internal controls and systems. We replaced ineffective transaction monitoring scenarios with stronger models that improved detection of suspicious activity. To strengthen people processes, we trained over three dozen analysts and investigators on investigative best practices and documentation standards. Finally, we improved executive visibility into the bank’s compliance monitoring efforts through real-time management information reports, which provided executives with accurate insights into caseloads, staff productivity and work quality.
The bank’s improved ability to detect and report suspicious activity reduced its enforcement risk and reinforced its commitment to staying ahead of compliance challenges and preventing financial crimes.
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.