BRG professionals conducted an AML gap analysis of a multinational corporation that facilitated the identification of high-risk products, clients, and geographies. The team reviewed the existing AML audit plan and modified it to address risks not assessed previously, as well as to include a better definition of relevant laws and regulations and corresponding controls and testing procedures. Overall, about 70 percent of the existing plan was modified and/or rewritten. The new version of the plan also included a summary of relevant laws and regulations applicable to the wholesale business in the US, with emphasis on the Patriot Act. The plan allowed business management to identify new BSA/AML related issues in critical areas such as trade finance and US sanctions compliance.
Note that some engagements may have taken place prior to the expert(s) joining BRG.