Featured Cases

A record of unmatched success.

Program Assessments

Our client, a large National Bank under regulatory scrutiny, retained Dominion to assess the bank’s financial intelligence operations. Dominion’s work included evaluating the FIU organizational structure and staff, transaction monitoring scenarios, completeness of alert and case resolutions, documentation practices for alerts and cases, quality control processes, high risk account detection, enhanced due diligence, management information reporting and metrics, and case management.

Dominion provided a comprehensive written report of the assessment findings, including those areas where the FIU operated effectively and those 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.

Program Development

Our client, a large National Bank, was under pressure from multiple government agencies for not identifying and reporting suspicious domestic and international activity. Within six weeks, our FIU development team replaced transaction monitoring scenarios that had failed to detect suspicious activity, trained over three dozen analysts and investigators on proper investigation techniques and documentation standards, and created reliable and consistent management information reports enabling executive management to obtain an accurate understanding of case loads, staff productivity and work quality. Dominion implemented a quality control process that ensured all alerts and cases were completed timely and accurately, helping the bank to avoid further criticism. We established new programs for addressing law enforcement requests, 314(a) requests and managing high-risk accounts.

Transaction Monitoring Optimization

Case #1

Our client, a large National Bank purchased a new transaction monitoring system and needed assistance with selecting scenarios, setting thresholds and developing workflow processes. Dominion tied the bank’s AML risk assessment directly to the selection of specific monitoring scenarios, ensuring risk presented by higher risk customers, products and locations was properly monitored. We completed a threshold testing and tuning cycle enabling the bank to accurately set criteria at which alerts would be generated. These settings helped the bank realize alert to case, and case to SAR ratios that far exceed the industry norms. In addition, Dominion created alert prioritization and assignment protocols ensuring higher risk alerts were resolved first and by the most qualified investigators.

Case #2

Our client, a large National Bank purchased a new transaction monitoring system and needed assistance with selecting scenarios, setting thresholds and developing workflow processes. Dominion tied the bank’s AML risk assessment directly to the selection of specific monitoring scenarios, ensuring risk presented by higher risk customers, products and locations was properly addressed. We also completed a threshold testing and tuning cycle enabling the bank to accurately set criteria at which alerts would be generated. These settings helped the bank realize alert to case, and case to SAR ratios that far exceed the industry norms. In addition, Dominion created alert prioritization and assignment protocols ensuring higher risk alerts are resolved first and by the most qualified investigators.

Case Management and Management Information Reporting

Facing the challenge of tracking the work of over 30 investigators, thousands of alerts, hundreds of cases, and dozens of SARs each month, our client asked Dominion’s FIU team to write the user requirements for an advanced case management system. Working with a software partner, the user requirements were turned into one of the industry’s leading case management software products. The client’s FIU workflow is now automated and as a result they save thousands of hours a year, track all FIU work, maintain all files electronically and provide the BSA Officer, management and the Board of Directors with accurate and useful metrics that measure staff performance, work quality and identify areas of risk unable to be identified prior to when the group relied on manual tracking.

Regulatory Response

A super-regional bank with a large retail network and several million customers was issued a Consent Order and faced having to rebuild its AML compliance program in a few short months. Dominion was retained to develop and staff an FIU department while new employees could be hired, write numerous policies and procedures, tune and test the existing transaction monitoring system, conduct a number of risk assessments and advise management and the Board of Directors on its monthly reporting requirements to the regulatory agency. The client was able to address each component of the enforcement action and subsequently have it lifted. The bank’s AML program is now regarded as among the strongest in the country and looked to by examiners as a model for how integrated AML risk management works.

Examination Assistance

A large regional bank seeking to double its size through a pending acquisition is told by its regulator that in order for the merger to be approved it must pass an upcoming BSA/AML examination. Dominion was retained to develop a process to identify high risk accounts and conduct due diligence as well as to develop investigation and quality control processes for all suspicious activity alerts. In addition, Dominion designed and implemented transaction monitoring reports while the bank was waiting for implementation of its new monitoring software. Dominion assisted management through the examination and its success enabled the bank to proceed with its acquisition plans.

Project Management

Faced with having to complete nearly 10,000 transaction-monitoring alerts in a short period of time, our client requested we organize staff, create business processes and manage completion of the work. Dominion worked with the client to hire qualified temporary workers who we then trained and whose work passed through our quality control process. We implemented a case management system and created management information reporting and key metrics that enabled the team of over 40 to complete its work on time and on budget. Just as importantly, our efforts enabled the client’s compliance management team to focus its energy on current operations and maintaining compliance.

High Risk Customers and Enhanced Due Diligence

Responding to a requirement issued in a Consent Order, our client, a large regional bank looked to Dominion to help build two key due diligence components. The first was implementing a program using software to risk rate customers at account opening based upon demographic characteristics and anticipated usage of products and services. Next, Dominion helped implement a process to perform enhanced due diligence (EDD) on high risk customers in accordance with the standards and expectations set out in the FFIEC BSA/AML Exam Manual. We developed comprehensive procedures for how to conduct EDD on numerous types of high-risk customers from MSBs, to PEPs, to cash intense businesses, to NRAs.

Backlogs of Alerts and Cases

Prior to an upcoming examination, a super-regional bank faced the daunting task of having thousands of alerts to resolve and investigations to complete. Dominion’s team of investigators, quality control specialists and project managers were retained to resolve each matter while allowing the bank’s FIU staff to continue to complete its ongoing work. Within three months Dominion resolved each alert and subsequent case, and upon review neither internal audit nor the bank’s regulator found any deficiencies.

Complex Investigations

A U.S. based international bank found itself the subject of an intense regulatory inquiry because one of its customers, a multi-country based foreign exchange business, was believed to have been involved in transferring ill-gotten funds from Latin America. Dominion’s senior investigators conducted a comprehensive investigation of the client, going back five years and unraveling a dozen companies and subsidiaries related to the principle. Our analysis covered thousands of international transactions in multiple currencies involving thousands of originators and beneficiaries. Ultimately our investigation demonstrated our client’s AML compliance program operated effectively and though the bank’s client was engaged in high-risk activity, the regulators did not mandate any significant changes to the AML program or issue any enforcement action.

Quality Control

Our client, a large National Bank had recently hired a group of investigators to address alerts produced by a new transaction monitoring system and needed to ensure the quality of work met FFIEC and FinCEN requirements. Dominion placed several of its quality control specialists in the bank’s FIU to review cases and SARs. In addition, the quality control team worked individually with investigators to train them on how best to complete cases and make sure SARs were accurate and would pass examination by the bank’s regulator. After a few months, the bank’s new FIU staff was performing strongly and all alerts and cases were completed timely.

Investigation Training

Our client, a large National Bank, needed to enhance how its FIU researched alerts and investigated cases. SAR quality did not meet the requirements of the FFIEC BSA/AML Examination Manual and many of the staff was new to AML. Dominion’s FIU development team implemented a two stage-training program. First we delivered our comprehensive training program, a two-day workshop where investigation principles and compliance with FinCEN standards are taught in an interactive classroom setting. Following the classroom training, Dominion’s team spread out to work side by side with investigators and analysts for several weeks as they applied the new standards. Within a month the FIU was completing investigations and filing SARs commensurate with industry best practice.

Look Backs

An enforcement action brought on by a faulty transaction monitoring program, mandated this National Bank undertake an 18 month look back of customer cash, wire, remote deposit capture, and MSB related activity. Dominion’s Look Back team formulated a plan, approved by the regulators, and quickly deployed our alerting and case management tools as well as our highly trained investigators, quality control and project managers to complete the look back ahead of schedule and under budget. The regulators approved the final look back report and the client was able to avoid any additional fines or penalties.

Department of Justice Investigations

The actions of past and current management were under investigation by the Department of Justice and the bank needed a firm that could dive deeply into prior program weaknesses and provide the government the confidence it needed to step back and give the bank time to resolve its issues. Dominion worked closely with the bank’s outside counsel to provide government investigators and regulators information they needed and thus removed the need for federal agents to rummage through bank records, descend on the bank’s staff, and turn operations upside down. The investigation was eventually resolved with the imposition of a Deferred Prosecution Agreement and a civil money penalty.