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. W1G 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 commence with reviews of FCC compliance programs as “regulatory audits” and assess according to regulations, W1G proactively assesses according to detection of threats and the risks of financial crimes occurring or potentially occurring in the Client’s business. From there W1G works to eliminate the threats and proposes solutions to close the gaps to ensure regulatory compliance manner.
With personnel possessing decades of forensic financial crimes expertise in law enforcement, W1G is often called upon to conduct targeted internal investigations for the benefit of corporate management as well as 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 W1G 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 a 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.