A financial institution with approximately $5 billion in assets was facing increased scrutiny within its compliance department following the appointment of a new general counsel. With a desire to ensure the compliance function was aligned with regulatory expectations and internal standards, leadership sought our expertise to assess operations, identify vulnerabilities, and recommend a path forward. Prior to our engagement, there was no comprehensive effort to evaluate or realign the compliance department’s people, processes or controls.
We began with an in-depth scoping effort, conducting interviews with senior management to surface critical compliance concerns and related processes. From there, we crafted a detailed project scope that prioritized key operational and functional areas for improvement.
To build alignment across the organization, we facilitated a full-day session with stakeholders from multiple compliance units. This collaborative session enabled us to map current-state processes, identify process gaps, and outline a shared vision for a future-state compliance function. Tangible deliverables included flowcharts, gap analyses, and actionable recommendations.
Our team developed a comprehensive implementation plan that spanned all stages of execution—from initial rollout to final walkthrough. As part of that work, we documented Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) procedures, re-evaluated and tested high-risk transaction rules in the bank’s Prime BSA system (which had been generating excessive false positives) and introduced new business logic to increase detection accuracy.
We also delivered a Compliance Risk Assessment and accompanying Compliance Test Plan, ensuring a proactive approach to monitoring and managing risk. Finally, to support day-to-day leadership continuity, we placed an acting Chief Compliance Officer to guide the transition and provide executive oversight.
Through our structured approach and deep compliance expertise, we helped the bank address previously unidentified gaps and strengthen its overall compliance posture. We provided actionable insights and implemented sustainable improvements, including refined operational documentation, a robust annual risk assessment, and an aligned compliance testing framework. Our work empowered the bank to confidently meet regulatory expectations and build a more resilient compliance function—well-positioned for future growth and oversight.
