Our Featured Cases
At the outset of the Ukraine–Russia conflict, a large U.S.-based wealth management firm with many international clients and alternative investment fund accounts became concerned about the risk of indirectly holding and managing funds from sanctioned individuals and entities.
Uncovering potential nested accounts and unknown beneficial owners required considerable data mining skills, expertise, and experience unraveling complex corporate and investment fund structures in high-risk locations such as Cyprus, Switzerland, and Monaco.
The client retained Dominion’s multi-disciplinary team of technology, data extraction, and filtering experts and our senior special investigators with years of experience tracing international funds movements, alternative investment partnership understanding, and opaque ownership trails to identify, investigate, and identify several hundred entities related to sanctioned parties whose funds were hidden in limited partnerships and other hard to unravel investment vehicles.Read More
M&A – AML Program Integration
A traditional U.S. retail and commercial bank had recently acquired a bank with a growing crypto and digital assets services business with little time to conduct thorough due diligence. The acquirer bank was concerned about the unknown level of AML and fraud risk it was now responsible for identifying, assessing, and managing.
The acquirer’s AML and risk team were fully occupied with existing operations, and with the acquired bank considered extraordinarily high risk, management, the board of directors, and regulators needed to move quickly to ensure the acquired institution’s controls and compliance were bolstered immediately.
Dominion’s senior team of program experts assessed both institutions’ software systems, operations, policy, and governance structures, recommending the best from each. We then wrote the detailed integration plan and led project management, combining the two programs’ operations, systems, and governance to manage a higher-risk profile client base and product suite.
A large retail bank with over 500 branches operating in more than ten states was on the cusp of receiving a Consent Order and faced having to rebuild its AML compliance program, including increasing staffing, purchasing new software systems, and upgrading all policies and procedures.
Dominion was retained to assess, design, and staff an FIU department. At the same time, our team wrote numerous policies and procedures, tuned and tested the existing transaction monitoring system, created transaction monitoring models, conducted risk assessments, and advised management and the Board of Directors on its monthly reporting requirements to the regulatory agency.
We assisted the bank in hiring dozens of FIU staff and, once onboarded, trained each analyst and investigator individually and built and operated a Quality Control team, ensuring every alert and case investigation was completed correctly. Dominion wound down our operation and handed a fully functioning, fully compliant FIU to the bank.Read More
Investigation Support Services – Fraud
A superregional bank operating in more than 15 states with more than 1,000 branches found itself unable to keep up with the workload created by PPP loan fraud investigations and had no available people to start and run the new group. Needing a team of experienced fraud investigators able to deploy quickly with little to no ramp-up time, this long-time Dominion client sought our help.
Within a week, we assigned 25 experienced fraud analysts and investigators to create and operate a PPP fraud investigation team. We developed procedures, workflow systems, tracking, and reporting protocols. Dominion ran the team for six months, at which point we transitioned the operation to the client. Building and staffing the new PPP loan fraud team enabled the bank’s ongoing day-to-day fraud detection, investigation, and reporting operations to run without interruption.
Investigation Support Services – AML
Several years after a large acquisition, our client, a superregional bank operating in 20 states with nearly 2,000 branches, discovered that when the programs of the two institutions were merged, several critical alerting systems were not operating. This created a large backlog of matters existing staff could not address without jeopardizing day-to-day operations.
The client turned to Dominion. Within two weeks, we had 15 experienced AML investigators ramp up and chipping away at the backlog. After Dominion’s initial surge of investigators stabilized the backlog, the client requested, and we provided additional staff, including Quality Control reviewers. To help work down the backlog, the client also retained three additional large consulting and investigation firms. One by one, each of the three was wound down as they were unable to keep pace with and produce the quality of Dominion’s team.
The client retained Dominion as its co-source partner in its day-to-day ongoing investigation operation.
AML Program Assessment
Our client, a large National Bank, was under pressure from regulatory and enforcement agencies for not identifying and reporting suspicious domestic and international wire activity.
Dominion was retained to quickly evaluate the FIU organizational structure and staff, transaction monitoring scenarios, accuracy and completeness of alerts and cases, quality control processes, high-risk account detection, enhanced due diligence, management information reporting, and case management.
We delivered a comprehensive written report of the assessment findings, including those areas where the FIU operated effectively and where the FIU needed to improve. We provided a corrective action plan that included the timing, cost, and effort necessary to implement each recommended improvement.Read More
Investigation Services – Enhanced Due Diligence
A large top 15 national bank operating in over a dozen states had just implemented a new Customer Risk Rating system. It was unprepared for the number of new Medium and High-Risk Customers requiring Enhanced Due Diligence. Without the existing staff to manage the new work, they called Dominion.
Arriving with a team of ten, we quickly set up workflow systems, created templates, set up quality reviews, and began researching each client. Growing from 10 to 60 staff in a month, we cleared the backlog and stabilized ongoing operations. As the bank built the new unit, Dominion’s experienced investigators trained new staff, oversaw quality control, and were able to hand off a fully operational EDD unit.
Complex Fraud Investigation
A large international payment processor was concerned about rapid growth among a set of merchants. One group of merchants was popping up, running numerous cards through processing and then disappearing. Another merchant saw transaction growth at a rate that appeared out of the ordinary. Needing assistance running an extensive international investigation, the payment processor retained Dominion.
At the beginning of the investigation, our team discovered that a large domestic payments company provided merchant services to new businesses where little due diligence was done, and internal monitoring systems failed to uncover high-risk behavior. In these cases, so-called merchants were approved for transaction access. Instead of selling legitimate goods, the merchants used the payment company to run card numbers to test whether they were active and available. Once the phony merchants ran what were later discovered by Dominion investigators to be stolen credit card numbers, they would disappear and then use the active numbers elsewhere to purchase goods.Read More
Complex High-Risk Customer Investigation
Initially retained by a large national wealth management and private bank, Dominion investigators were completing the assessment of current FIU operations and supplementing the investigation team staff when we discovered a series of unusual transactions involving a Politically Exposed Person.
Assigning one of our forensic investigation experts, who led a small team of analysts, we uncovered layers of shell companies, intermediaries, and other cut-outs that masked the true nature of the millions of dollars in international wire transfer activity from and to high-risk European countries and banking centers.
Realizing the results of this investigation were likely to grab the attention of the Department of Justice and the news media, the team worked to create a “court-ready” investigation file detailing several years of transactions and multiple layers of opaque shell company ownership. The investigation did end up making international news and resulted in a multi-month trial in which convictions for money laundering were won.