Anti-Money Laundering and Sanctions Advisory

We assist in designing, assessing, and transforming enterprise AML and sanctions compliance programs. We combine industry-specific knowledge with demonstrated methodologies to assess the effectiveness, efficiency, and efficacy of our clients’ AML and sanctions compliance programs and recommend enhancements. Our capabilities specific to AML and sanctions compliance include assessing governance and oversight activities, evaluating policies and procedures, testing controls, and evaluating reporting and communication.

We help organizations effectively manage risk and meet regulatory expectations by assisting across the elements of their global KYC program, including policies and procedures, client risk rating models, KYC operating models and data management, and customer due diligence and enhanced due diligence. We also provide a broad range of KYC services that can assist organizations to uplift customer files to new standards. Using our KYC operations playbook, proprietary KYC tool—the Enterprise Case Manager (ECM)—and flexible on and offshore delivery and staffing models, we work to help you effectively and efficiently meet KYC operations objectives and timelines.

Deloitte’s AML Managed Services deliver quality outcomes leveraging more than 15+ years of experience and investment in AML talent, processes and technology to solve your most critical AML needs. Our KYC and AML Transaction Monitoring Managed Services are underpinned by a market-tested operational playbook, our proprietary Enterprise Case Manager (ECM) technology platform, and dedicated global on-and offshore-AML operations delivery centers. Our AML Managed Services are customized to meet your specific needs and deliver quality outcomes at high levels of efficiency and compelling economics.

We measure and document the AML and sanctions risk arising from factors specific to each line of business and at the enterprise level, including customer base, products and services, transactions, geographies, and delivery channels. We further assess external threats and national priorities that impact your institution in the various markets it operates in. Last, we capture detail on scope and effectiveness of controls such as policies, procedures, and processes used to manage AML and sanctions risk. Through these activities, we can provide an assessment of inherent AML and sanctions risk levels and an assessment of the control processes in place to manage those risks. Through our proprietary technology, Deloitte Enterprise Risk Assessment (DERA)—a web-based, standardized, and automated tool—we offer a flexible and scalable platform that can be configured to each client’s needs across its organization.

Risk Assessment Short Perspective

Transaction monitoring is a key component to an organization’s efforts to mitigate financial crime risk. We assist institutions in assessing and optimizing current transaction monitoring rules and models and improve the process to detect, prevent, investigate, and report suspicious activity. We also help our clients develop new approaches and models to better detect financial crime. We have experience in the areas of Office of Foreign Assets Control (OFAC)/Sanctions transaction analyses, suspicious transaction reviews and lookbacks, currency transaction reviews and lookbacks, and internal investigations.

Financial organizations rely on automated technologies and systems to detect and prevent money laundering and other suspicious activities. Automated monitoring has employed more quantitative and automated techniques over time. Deloitte’s model validation methodology is designed to assess the key elements quantitatively and qualitatively as outlined in regulatory guidance. We have experience conducting model validations for small-, mid-, and large-sized financial institutions across multiple lines of business. We have conducted model validations for a range of models using both commercial off-the-shelf and customized proprietary models.

Organizations need to understand data and make informed decisions regarding their AML and sanctions technology as a critical component of a comprehensive AML and sanctions program. We have a dedicated AML analytics team and a wide range of AML and sanctions technology services to assist clients with this need. We can help with AML and sanctions technology system assessments, source data quality and integrity evaluations, customer segmentation and customer risk solutions, transaction monitoring tuning and case management, and alert/case scoring development.

In today’s enforcement-minded regulatory environment, money laundering risks should be managed at the highest levels of an organization and driven into each line of business. This means having an effective target operating model; documents that set out roles and responsibilities, reporting, and escalation processes; and other indicators of a clear program process. We can create customized training for the board of directors (board) and senior management and help coordinate the financial institution’s goals with the overall training and program. Progress is tracked through risk and performance indicators, risk assessments, gap assessments, and testing results that highlight strengths and shortcomings that can then be addressed by the board and senior management.

Financial institutions are required by regulators to conduct independent testing of their Bank Secrecy Act (BSA)/AML compliance programs. These tests are also an opportunity to identify and correct deficiencies in existing programs and assist an organization’s management team in preparing for regulatory examinations. We help our clients by testing the effectiveness of their BSA/AML program including their people, documentation, processes, and technologies.