Operating across multiple states, the bank had recently deployed a new Customer Risk Rating system that significantly increased the number of medium- and high-risk customers requiring enhanced due diligence. Compounding this challenge, a public enforcement action had identified critical weaknesses in the bank’s transaction monitoring and investigative capabilities, including a reliance on “capping” alert volumes based on available staffing rather than actual risk.
The existing compliance team lacked the capacity to process the growing backlog of alerts and conduct the necessary due diligence, putting the bank at risk of non-compliance and regulatory penalties. Without a scalable, structured approach, the institution faced operational inefficiencies and ongoing scrutiny from regulators.
SolomonEdwards’ Financial Crimes practice, formerly known as Dominion Advisory Group, rapidly deployed a team of experienced investigators, beginning with an initial group of 10 specialists to stabilize the backlog. Recognizing the need for both immediate impact and long-term sustainability, we designed and implemented a two-tiered investigative approach, where junior analysts resolved routine alerts while senior investigators handled escalations and potential Suspicious Activity Report (SAR) filings.
To address staffing deficiencies, we launched a multi-week training program to onboard 60 analysts on the new investigative framework, ensuring consistency in approach and adherence to regulatory expectations. We also embedded quality control measures by requiring investigators to submit their findings to experienced professionals for review.
Leveraging our expertise in workflow optimization, we collaborated with the bank’s IT team to develop a proprietary quality control workflow tool. This system captured investigation results, generated reports and identified areas for improvement, enabling management to monitor quality, productivity, case disposition and SAR filings. Additionally, we conducted an in-depth evaluation of the bank’s transaction monitoring system, testing over 200 rules and recalibrating thresholds to align with actual risk exposure.
To remediate concerns about alert volume capping, we launched a retrospective review project, resulting in the processing of thousands of alerts and hundreds of SARs under the new compliance framework. We also developed staffing models and schedules to demonstrate to regulators and senior management the appropriate department size required to handle the increased workload.
Through our structured approach, the bank successfully cleared its backlog, strengthened its transaction monitoring framework and demonstrated regulatory compliance. Our enhancements to quality control, management reporting and workflow efficiencies positioned the bank for sustainable operations, ultimately leading to the lifting of the enforcement action.
By the end of the engagement, the bank’s internal teams were fully equipped to manage ongoing compliance needs, having gained the necessary expertise and infrastructure to maintain an effective due diligence program. Our collaboration enabled the institution to not only resolve immediate regulatory concerns but also establish a more robust risk management foundation, allowing for future growth and expansion.
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.