Client Challenge

Facing an Enforcement Action for BSA Compliance Program weaknesses, our client needed to implement a transaction monitoring system while simultaneously building, staffing and training a Financial Intelligence Unit to analyze transaction alerts, conduct investigations and file complete and accurate SARs.

The Dominion Solution

Dominion’s approach was multifaceted and moved rapidly. First we provided a comprehensive written plan for how to approach the organization, staffing and management of the FIU. We then placed a team of our monitoring analysts and investigators with the client to immediately begin working any existing and backlog investigations so as not to increase the client’s compliance risk, while simultaneously providing training to existing and new bank staff on methods to properly conduct analysis and investigation on potentially suspicious activity.

Concurrent to this work, we assisted the client’s technology staff in the implementation of the new monitoring software and provided expertise on how to tune and calibrate the software’s monitoring thresholds to ensure our client was receiving the most meaningful transaction alerts and not deluged with report after report of information that would be of little use.

We also provided a team of EDD specialists to assist in the design and implementation of a program to conduct research and on-going risk management of the bank’s highest risk customers. We also wrote comprehensive written procedures and developed case management software to facilitate the effective flow of work and to ensure consistency of standards from one EDD review to the next.