A prominent private bank came under regulatory pressure when the Office of the Comptroller of the Currency (OCC) issued a consent order citing violations of the Bank Secrecy Act (BSA) and anti-money laundering (AML) standards under the USA Patriot Act. The mandate triggered a comprehensive remediation effort, compelling the institution to conduct a full review of its compliance procedures and customer accounts. The bank responded by engaging a Big Four firm to lead a retrospective analysis of over 7,000 new accounts opened during a four-year period.
This effort was large in scale and critical in importance. The scope spanned multiple locations and demanded a rigorous compliance process that included enhanced customer due diligence, risk-based Know Your Customer (KYC) assessments and in-depth transaction reviews. The bank also needed to ensure appropriate Suspicious Activity Report (SAR) filings were made—quickly and accurately. Speed and accuracy were non-negotiable, with reputational and regulatory consequences hanging in the balance.
We were brought in as the lead investigative and remediation team by the bank’s executive leadership. Working alongside the Big Four auditor, we orchestrated a highly structured and collaborative solution that addressed both immediate compliance needs and long-term risk management goals.
Our team led the entire remediation initiative over 18 months, managing four dedicated work streams and deploying a team of 100 consultants to execute the project across seven regional locations. Direct coordination with relationship managers ensured that frontline staff were trained, informed and supported throughout the process.
To reinforce sustainable change, we designed and implemented robust governance frameworks. This included the creation of a centralized quality control department—a critical measure to help the bank maintain its compliance posture well beyond the lifecycle of the project.
The results were clear and significant. The OCC consent order was successfully lifted, halting further regulatory action and signaling a return to compliance. Internally, the bank saw meaningful improvements in operational efficiency, thanks to better processes, greater consistency and tighter controls.
Perhaps most importantly, the effort restored confidence—among regulators, executives and clients alike. The bank emerged from the challenge not only in compliance but better equipped for long-term success.