Financial Crime Compliance (“FCC”)/Anti-Money Laundering (“AML”)
W1 Global helps Clients identify and mitigate the risks that are inevitably present within the scope of international business relationships. We work with our Clients to develop compliance controls, due diligence procedures and investigative skills that are tailored to their needs based on their business model and industry specific risks.
FCC Program Review, Design & Execution
Financial Crime Compliance (“FCC”) is replacing the term Anti-Money Laundering (“AML”) Compliance because it is more encompassing. However, the two terms are often used interchangeably. W1 Global offers a complete array of program review, design and execution (i.e. implementation) to all entities required to develop such programs all over the world. Most of our Clients are financial institutions (including banks, broker dealers, insurance companies, asset management companies and hedge funds), law firms and intermediary service providers such as accounting firms.
Whereas the approach of most consulting firms commences with reviews of FCC compliance programs as “regulatory audits” and assesses according to regulations, W1 Global proactively assesses according to detection of threats and the risks of financial crimes occurring or potentially occurring in the Client’s business. From there we work to eliminate the threats and propose solutions to close the gaps to ensure regulatory compliance and business optimization.
With personnel possessing decades of forensic financial crimes expertise in law enforcement, W1 Global is often called upon to conduct targeted internal investigations for the benefit of corporate management as well as to assist FCC employees with an investigation involving one of their customers. Such FCC investigations may take the form of a complete review of a person or entity’s profile in conjunction with a forensic analysis of financial activity, and/or a substantial due diligence report involving information gleaned through a series of public and confidential sources (i.e. a “Level II” report). Not only are the reports of such undertakings provided by W1 Global provided to management in a clear manner, substantiated with facts and analysis; they also possess pragmatic solutions and options that management can use to steer their business and mitigate risks.
In many cases, we also recommend working an investigation in conjunction with internal FCC personnel. Such engagements are particularly beneficial to Clients because their staff learn (1) to expand their scope of an investigation, which is often too narrow in the context of defined bank regulations; (2) expand their expertise with regard to the analysis undertaken within the investigation; and (3) learn to write more comprehensive and accurate Suspicious Activity Reports (“SARs”) that are submitted to the appropriate government authorities. Furthermore, the trends and assessments of the investigations, when properly tracked and analyzed, are powerful tools to assess the quality of a company’s FCC program, and identify and remedy gaps or weaknesses.
W1 Global excels at delivering practical training to empower employees, senior officers and executive management to identify and mitigate the threats they face regularly. Members of the W1 Global team have trained thousands of people from various financial institutions and corporate enterprises as well as government officials from dozens of countries. Training is customized based on the profile of the institution and the risks it faces. Training can be targeted, for example, on matters pertaining to the conduct of an investigation; assessing risks of Clients, industries or jurisdictions; and, training/advising executive officers and board members as to the scope of responsibility and determining optimal courses of action. W1 Global applies “real life” events as experienced by the institution to its training presentation, and creates an interactive environment that not only teaches personnel how to identify risks, but also how to deal with them.