BRG financial crimes compliance (FCC) professionals advise all types and sizes of firms, including US and non-US banks, virtual asset service providers, fintechs, money service businesses, insurance and mortgage companies, and other financial institutions. With in-depth knowledge of industry practice around the world, we tailor programs, technology, and advanced analytics to each client’s size, complexity, and risk profile, delivering insights and practical strategies.

BRG professionals have advised financial institutions in the development and enhancement of programs to comply with anti-money laundering (AML) laws such as the Bank Secrecy Act (BSA), USA PATRIOT Act, the Anti-Money Laundering Act (AMLA); Know Your Customer (KYC) laws and Financial Action Task Force (FATF)–issued recommendations; counterterrorism and sanctions laws such as those promulgated by the United Nations and administered by the US Treasury’s Office of Foreign Assets Control (OFAC) and UK HM Treasury’s Office of Financial Sanctions Implementation (OFSI); and anti-bribery and -corruption laws such as the Foreign Corrupt Practices Act (FCPA), UK Bribery Act, and other laws based on the United Nations Convention against Corruption.

BRG’s expertise is particularly valuable in addressing enforcement actions, identifying emerging issues, developing regulatory strategies, and enhancing efficiency and effectiveness. BRG professionals have significant experience working with financial regulators throughout the world. We have worked extensively with federal regulators in Washington, DC, US state banking departments, and throughout Europe, the United Kingdom, Africa, the Middle East, Asia, and Latin America.

Our services span the FCC spectrum and include:

Program Design and Implementation

Our experts design and implement effective FCC programs for institutions of all sizes and complexities, across geographic and product footprints. Services include:

  • Designing target operating models for enterprise-wide FCC governance across all lines of defense and business
  • Developing programs for new bank charters and licensing for new banks, fintechs, and digital assets and virtual assets firms
  • Conducting enterprise-wide risk assessments
  • Enhancing internal controls, including policies and procedures, KYC processes (including beneficial ownership), customer risk rating, training, and quality assurance and quality control

Regulatory Response and Engagement

Our experts have assisted dozens of financial institutions in responding to and addressing regulatory criticism and have served as independent monitors in enforcement matters. Services include:

  • Preparing for supervisory exams and regulatory engagement
  • Responding to enforcement actions, including rapid action planning and designing change management programs
  • Enhancing and remediating controls and addressing inherent risks that exceed tolerance
  • Supplementing resources with expertise at all levels in the compliance program, from analyst to interim chief compliance officer roles

Lookbacks, Forensics, and Investigations

Our experts design and perform lookbacks and reviews of all sizes, covering transaction monitoring, sanctions and export controls, and KYC due diligence, including:

  • Scoping, designing, and defending lookback methodologies and sample selections
  • Identifying, collecting, and transforming lookback data, including on premise and in secure environments
  • Executing lookbacks, reviews, and investigations, including deploying technology and platforms, staffing and management, quality assurance, metrics, and reporting

Emerging and Specific Risks

We help our clients identify, evaluate, and address emerging risks and industry hotspots, including:

  • The emergence and institutionalization of digital and virtual assets
  • Continued risk associated with correspondent banking and trade finance (including trade-based money laundering)
  • Higher-risk customer types, including money service businesses, nonresident aliens, politically exposed persons, and professional service providers
  • New services, such as crowdfunding, peer-to-peer lending, new payment methods and facilitation, and P2P and B2B payments
  • New and unique typologies, such as wildlife trafficking, antiquities, precious metals smuggling, and human trafficking

Systems, Technology, and Data

Our experts are solution-agnostic and work closely with incumbent and challenger platforms and BRG’s Global Applied Technology and data governance teams. Services include:

  • Defining business and functional requirements and assisting across the system implementation process
  • Establishing data governance and integrity frameworks for effective implementation
  • Tuning and calibrating tools for transaction monitoring, name screening, and risk rating
  • Performing model validation and providing independent assessment of associated data for lineage, quality, and appropriateness

Advanced Analytics and Program Transformation

Our experts work with clients to transform their FCC and KYC programs, applying machine learning, analytics, and reporting to enhance digitalization and address systemic challenges. Services include:

  • Applying machine learning and artificial intelligence (IA) to reduce false positives and false negatives while enhancing customer and employee experience
  • Designing next-generation customer risk models and tools that drive efficiency and effectiveness
  • Reengineering processes to integrate new technology, process automation, and evolving fintech and regtech solutions

Professionals

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