AML outside examinations
As longtime readers know, we have a long history of locating concealed assets in fraud (which largely move from the United States to exotic places overseas), and, somewhat more recently, of developing AML programs (largely in exotic places overseas). Our goal is to develop AML programs that are not only compliant, but that also address the crimes they are supposed to detect, and that don’t impede the flow of business.
Considering the nature of our domestic and international fraud and AML experience, it was only a matter of time before we moved to the arena of performing the mandatory independent AML examinations required of many financial gatekeepers, and the repair of defects found. If you have such a statutory requirement, we hope you will engage us to assist you with this.
It is important to understand that AML is a core competency for us, so that your team will be made up of experienced people. And that we bring to it not only an understanding of compliance issues, but also an understanding that AML is about fraud and other financial crimes. This means we can help assure that you are not hit with a cease-and-desist order for having a program that was developed for form rather than substance; that was aimed at merely being compliant rather than at stopping crime.
Besides those financial gatekeepers that at present have AML requirements under the Bank Secrecy Act, there are also a host of industries that will soon have these requirements to meet. The most vulnerable of these include hedge funds, futures commission merchants, private equity funds, and unregistered investment funds.
If your company falls into these categories, we hope you will hire us, so you can be ready to drop these systems in place when these requirements are extended to you.