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Anti-Financial Crime

Responding to the Increased Global Risk of Financial Crimes

The risk of financial crimes is high in today’s global, technology-driven economy, and takes many forms, including bribery and corruption, money laundering, sanctions breaches, insider trading, human trafficking, and terrorist financing. Wrongdoers remain innovative in devising and deploying methods to perpetrate financial crimes, leveraging knowledge and cutting-edge technologies to expose and exploit weaknesses.

Financial crime continues to be one of the most significant challenges facing businesses today. It persists as a key concern for governments and regulators globally, with additional legislation and stricter protocols being prioritized and regularly implemented. Scrutiny is intensifying with enforcement escalating as regulators embrace international cooperation, launch specialized task forces, and take a much more aggressive position in their fight against financial crimes.

The Ankura Anti-Financial Crime (AFC) experts know that each organization’s business, people, processes, and systems are unique and require bespoke solutions that are fit for purpose. When advising clients, we supplement our unique blend of subject matter expertise (SME), cross-functional experience, and global reach with advanced data analytics expertise and technology solutions. Our experts design innovative approaches and strategies tailored to an institution’s specific circumstances and challenges.

We routinely leverage deep technical knowledge and industry-leading tools on Anti-Money Laundering (AML), lookback and Counter-Terrorist Financing (CTF) investigations, white-collar crime and fraud investigations, Anti-Bribery and Corruption (ABC) matters, and other critical legal, regulatory, and compliance projects.

Entities we work with:

  • Financial Institutions (nationally charted and community banks, credit unions, de novo banks, etc.)
  • Offering gaming and betting products and services
  • Money Service Businesses
  • Broker-Dealers
  • Registered Investment Advisors
  • Casinos and other gaming operators
  • Cannabis-Related Businesses
  • Offerings

    Regulatory Compliance & AML

    Tailored solutions designed to help minimize the risks associated with money laundering and/or other illicit activities and to ensure compliance through the development and management of ongoing compliance and monitoring processes.

    • Draft, evaluate, and enhance policies and procedures, compliance and audit programs, and governance and oversight frameworks.
    • Conduct regulator-mandated lookback reviews and monitorships.
    • Creation and implementation of remediation plans.
    • Support implementation of transaction monitoring systems.
    • Perform AML model validation, testing, and tuning.
    • Conduct independent compliance tests including independent AML reviews, consumer and lending compliance reviews, Automated Clearing House (ACH) reviews in accordance with National Automated Clearinghouse Association (NACHA) rules, and bank partner due diligence reviews.
    • Perform gap analyses and issue recommendations and action plans to achieve the desired future state.
    • Provide investigative support to clear alert backlogs.
    • Facilitate communications with relevant stakeholders and local authorities.
    • Advise and assist with the implementation of regulatory requirements, internal operational standards and best practices.
    • Assist in the preparation for regulatory exams.
    • Innovate and automate AML monitoring systems to aid in fulfilling law enforcement requirements in a more efficient and effective manner.
    • Act as the internal compliance function for clients by implementing and maintaining the company’s compliance program and assisting in performing day-to-day compliance operations tasks.
    • Prepare and file regulatory reports such as FinCEN registrations and renewals, Suspicious Activity Reports (SARs), Currency Transaction Reports (CTRs), and Foreign Bank and Financial Accounts (FBARs).
    • Develop, enhance, and facilitate AML training.
    Risk Assessments

    Tailored solutions designed to help identify and reduce the likelihood of risks that could negatively impact an organization’s ability to conduct business.

    • Prepare or conduct a variety of risk assessments including AML/CTF risk assessments, customer risk assessments, country risk assessments, fraud risk assessments, and product/service risk assessments.
    • Evaluate and enhance existing risk assessment policies and procedures.
    • Re-evaluate legal, political, and operational risks attributable to regulatory developments, and regime or policy changes.
    • Design and implement continuous monitoring dashboards to convey key risk indicators to key stakeholders.
    Know Your Customer (KYC)/Know Your Business (KYB)

    Tailored solutions designed to help verify customers and know their risk and financial profiles.

    • Evaluate and enhance KYC/KYB policies and procedures.
    • Advise and assist with the implementation of KYC/KYB enhancement initiatives, including the identification and verification of customers and business partners.
    • Conduct general Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) during the customer onboarding process.
    • Evaluate complex ownership and control structures.
    • Identify beneficial owners and perform risk classification of customers.
    • Assist and guide in the selection, vetting, and configuration of KYC/KYB platforms/tools.
    • Conduct KYC/KYB and onboarding checks on behalf of the client.
    Transaction Monitoring (TM) & Suspicious Activity Report (SAR) Filings

    Tailored solutions designed to help track and analyze ones activity to identify suspicious transactions or behavior patterns that may indicate fraud or money laundering.

    • Support the implementation of TM systems.
    • Design TM scenarios and rules customized to the portfolio and client base of the financial institution.
    • Assess coverage of TM systems to ensure the overall effectiveness and efficiency rates of the TM rules and to identify areas for enhancement and remediation.
      • Provide investigative support to clear TM alert backlogs.
      • Assess the efficiency and effectiveness of TM scenarios based on SAR filings.
      • Provide case-handling support to ensure effective and efficient escalations and compliance with reporting obligations.
      • Conduct manual transaction monitoring in the absence of automated TM systems.
      • Perform transaction monitoring, in the client’s chosen TM system, to clear alerts.
      • File SARs on activity for the client.
      • Outsourced Bank Secrecy Act (BSA) administration (for U.S. entities) covering day-to-day BSA operations using the client’s TM systems to accomplish BSA duties and responsibilities of regulated financial institutions.
    • Tax fraud monitoring and reporting.
    Anti-Bribery & Corruption (ABC)

    Tailored solutions designed to help identify, manage, prevent, respond to, and monitor risks of misconduct relating to bribery and corruption.

    • Draft, evaluate, and enhance ABC risk assessments.
    • Review internal corporate policies, procedures, and processes for effectiveness and compliance, and identify regulatory and operational gaps
    • Review, evaluate, and optimize identified system, control, and process weaknesses.
    • Create and execute risk-based action plans.
    • Provide comprehensive guidance for compliance with the Foreign Corrupt Practices Act (FCPA), UK Bribery Act 2010, and other regional regulations.
    Sanctions & Embargoes

    Tailored solutions designed to ensure sanctions & embargoes laws compliance and minimize the risk of sanctions breaches.

    • Design, enhance, and/or help implement sanctions screening programs.
    • Perform sanctions risk and coverage assessments.
    • Provide individual advisory services for management and supervisory bodies on topics related to sanctions.
    • Conduct sanctions, embargoes, and politically exposed person (PEP) screening, watchlist guidance, and adverse media search.
    • Provide guidance on effective and efficient solutions to internal and external audit findings and assistance with the implementation of such solutions.
    • Perform independent testing and model validation for sanctions screening systems.
    • Conduct a review of correspondent banking relationships for potential sanctions risks.
    • Develop, enhance, and conduct sanctions and watchlist training.
    Anti-Tax Evasion Facilitation

    Tailored solutions designed to help prevent tax evasion and the facilitation of tax evasion in the jurisdictions in which our clients operate.

    • Develop accounting, valuation, and economic analyses to resolve issues at audit, appeal, or otherwise narrow the topics in dispute.
    • Assist in dealings with opposing counsel and their experts prior to the exchange of expert reports in legal proceedings.
    • Provide the foundation for testimony by financial, industry, economic, or technical experts.
    • Assist in the navigation of complex financial systems, global operating structures, and inter-company accounting methods to uncover actionable insights.
    Consumer Compliance

    Ensure compliance with regulatory consumer protections and minimize the risks associated with consumer compliance violations.

    • Consumer Compliance coverage includes the following regulations: Regulation E, Unfair, Deceptive, Abusive Acts & Practices (UDAAP), the Gramm-Leach-Bliley Act (GLBA) Privacy and Complaints Management, and General Data Protection Regulation (GDPR).
    • Draft, evaluate, enhance, and implement consumer compliance programs including policies and procedures and governance and oversight frameworks.
    • Draft and enhance required consumer compliance disclosures.
    • Perform risk assessments.
    • Provide consumer compliance training.

    Minimize the risks of fraudulent activity by ensuring a comprehensive fraud program to prevent, detect, and monitor fraudulent activity.

    • Draft, evaluate, enhance, and implement fraud programs including policies and procedures and governance and oversight frameworks.
    • Design, enhance, and/or help implement fraud platforms, tools, and/or controls.
      • Perform fraud risk assessments.
      • Provide fraud training.
    Jurisdictional Licensing Acquisition

    Acquisition of state licenses for regulated money service business and virtual currency industries.

    • Serve as the project manager for the entire acquisition project and overall related parties.
    • Prepare and file state license applications electronically through the Nationwide Multistate Licensing System (NMLS) and by hard copy, according to state requirements.
    • Creation of all records pertaining to the NMLS filings (MU1, MU2, MU3, and MU4) for the company and control persons at the applicant, parent company, board, and investor levels.
    • Collection and creation of required personal disclosures, fingerprints, credit history, and third-party background checks for control persons at the applicant, parent company, board, and investor levels.
    • Liaise with state regulators leading into submissions and acting as the point of contact after submission.
    • Track and report on information needs and deficiencies from state regulators, milestones set and reached, regulatory communications, and status on progress.
    • Provide guidance on and acquisition of required surety bonds and insurances.
    • Obtain Secretary of State authority to transact business and trade name registrations in each state of operation.
    • Provide templates and guidance on drafting comprehensive business plans, financial projections, and flow of funds with narratives and diagrams to suit each regulator’s informational requirements.
    • Create or enhance existing BSA/AML)/Office of Foreign Assets Control (OFAC) policies, procedures, risk assessment, and Consumer Protection Compliance program policies and procedures.
    • Create or enhance existing fraud prevention, information security, disaster recovery, business continuity, and New York Rule Part 500 and Part 504 policies.
    • Register as a Money Services Business in local jurisdictions.
    Jurisdictional Licensing Maintenance & Administration

    Regulatory management and maintenance of state licenses for regulated money service businesses and virtual currency industries.

    • Maintain licenses in good standing and meet regulatory reporting filings.
    • Track, complete, and file all monthly, quarterly, semi-annual, annual, and other periodic regulatory reporting requirements according to each regulator’s requirements.
    • Track, complete, and file annual renewals needed for licenses, registrations, and surety bonds according to each regulator’s requirements.
    • Coordinate, prepare, file, and handle communications with state regulators with respect to the reporting of material events and transfers of control.
    • Track, analyze, and report the impact of changes in state regulations.
    • Conduct regulatory research on the implications of new products, services, and company designs.
    • Review and provide guidance on communications with the state regulators and law enforcement authorities.
    • Coordinate state regulatory examination including initial information requests, onsite processes, and post-examination interaction and remediation with state regulators.
    • Provide subject matter expertise for state regulatory examination execution and remediation.
    Secretary of State (SoS) Maintenance & Administration
    • Serve as the overall SoS and Registered Agent administrator, project manager, coordinator, and subject matter expert for Secretary of State and Registered Agent requirements.
    • Maintain legal entity and Doing Business As (DBA) registrations in good standing and meet filings and renewals.
    • Collect necessary information and prepare annual or biennial Secretary of State Annual Report filing requirements.
    • Prepare and file DBA/Trade Name renewals.
    • Prepare and file any material event, as needed, to include address changes, officer/director updates, etc.

    Our Latest Thinking

    Advisory in the Establishment of a Digital Asset Banking Division for a Bank

    Ankura was retained as a financial advisor in support of a state savings bank seeking to establish a regulated digital asset banking division offering cryptocurrency custody and another related service to its customers. Ankura professionals worked closely with management and other company advisors to evaluate the market opportunity and competitive landscape, prepare a draft business plan, develop cost and performance projections, and assess the anticipated impact on the bank’s stock price and regulatory capital ratios. Ankura prepared detailed materials for management and its board of directors, including valuing the digital asset banking division, as well as stock appreciation rights (SARs) with complex vesting criteria intended to be awarded to certain senior executives and directors in connection with the launch of the digital asset banking division.

    The Ankura Difference

    Ankura operates as one team across 35+ locations, providing professional and independent support to our clients, drawing on global talent, expertise, and local market knowledge seamlessly. We provide credible and independent expertise to assist our clients’ needs with sensitivity, tact, and balance. Our highly experienced SMEs and practitioners come from diverse professional and cultural backgrounds and will go above and beyond to ensure delivery outcomes that are fit for purpose. We have a full suite of risk management solutions, with active collaboration with our data & technology, disputes, restructuring, and transformation teams to provide you with a tailored service offering to manage risks in your business.

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