Client Challenge

A recent audit and compliance review revealed weaknesses in the bank's processes to identify and investigate suspicious activity.

The Dominion Solution

Dominion conducted an assessment of the bank's program to identify, analyze, investigate, document and report suspicious activity. We delivered a written report of recommendation on how to quickly improve the quality of suspicious activity detection and investigation efforts, including recommendations on organization structure, implementation of new monitoring systems, and development of new work processes.

We were then asked to assist the client in establishing new standards of analysis and investigation and to train new and existing staff on these standards. We also assisted in establishing a quality assurance program to review investigations and SARs to ensure adherence to FinCEN requirements and regulatory guidance. Our team of investigators augmented the client's staff in order to continue to investigate and report suspicious activity so as to avoid creating large backlogs of work while new monitoring systems, processes, and controls were being implemented.

Our transaction monitoring team assisted the client in developing new reports to detect suspicious cash and wire transfer activity and also assisted in retiring monitoring reports that were producing an abundance of alerts that rarely resulted in SAR filings.
Dominion's executive team provided advice and consultation to the client's executive management and board of directors on how to address key AML risk areas and address specific concerns of the regulatory examination staff.