The Investigation Process

The FFIEC BSA/AML Examination Manual states: “Banks must file SAR forms that are accurate, complete, and timely.” Failing to do so can lead to severe regulatory criticism. But implementing a strong suspicious activity reporting process can be the most challenging aspects of AML compliance.

Dominion implements suspicious activity report programs that have withstood dozens and dozens of audits and examinations. Our process is designed to adhere to FinCEN and FFIEC requirements and also be efficient and sustainable for our clients

The Enhanced Due Diligence Process

The FFIEC BSA/AML Examination Manual states:

The cornerstone of a strong BSA/AML compliance program is the adoption and implementation of comprehensive CDD (Customer Due Diligence) policies, procedures, and processes for all customers, particularly those that present a high risk for money laundering and terrorist financing. The objective of CDD should be to enable the bank to predict with relative certainty the types of transactions in which a customer is likely to engage. These processes assist the bank in determining when transactions are potentially suspicious. The concept of CDD begins with verifying the customer's identity and assessing the risks associated with that customer. Processes should also include enhanced CDD for high-risk customers and ongoing due diligence of the customer base.

The bank's responsibility is clear. The challenge is how to design, implement, and maintain an effective CDD and enhanced due diligence (EDD) process that identifies, researches, categorizes, and monitors high risk customers. Dominion implements just such programs that have successfully passed examination after examination.

Past Engagements

• Enforcement Action Response - $90 billion bank
• AML Program Assessment - $60 billion bank
• Transaction Monitoring Training - $55 billion bank
• Suspicious Activity Program Implementation - $50 Billion Bank
• Bank Wide AML Training - $20 Billion Bank
• Look Back Review - $1 trillion bank and $10 billion bank
• Insider Fraud - $1 billion corporation
• Staff Augmentation – Financial Investigations Units - $90 billion and $50 billion bank