Case Study

BRG Assists New York Branch of Global Bank in Responding to Joint Examination Report from FRBNY and NYDFS

January 1, 2018

BRG BSA/AML experts assisted the New York branch of a global bank in responding to a joint examination report from the Federal Reserve Bank of New York (FRBNY) and the New York State Department of Financial Services (NYDFS). The findings in the examiner’s report resulted in the client undertaking a comprehensive review of its BSA/AML risk management and compliance-monitoring processes, with a particular focus on compliance-monitoring functions including internal audit, cyber-security awareness, and sensitivity settings within the AML transaction-monitoring system.

Core elements of the customer-vetting and continuous-monitoring processes were enhanced and included elements of the Customer Identification Program (CIP), risk-based Customer Due Diligence (CDD), clearing of AML alerts and associated reporting, as well as ensuring that the Office of Foreign Assets Control (OFAC) screening and compliance processes were functioning as required.

BRG also assisted in evaluating the client’s AML system alert settings and, as appropriate, recommending modifications to the settings to ensure that the alerts were responsive to the findings in the joint examination report.

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