What We Do

Building compliant and sustainable AML Programs

Dominion has developed and implemented dozens of effective monitoring, investigation and sanction programs across the country, each of which have withstood intense audits and regulatory examinations. Dominion’s expertise in financial crime investigation, enhanced due diligence and the resolution of negative news/sanction alerts allows financial institutions to scale their program to match customer growth, product changes and new regulations.

Program Assessments

The strength of an AML compliance program is largely dependent on the effectiveness of an institution’s Financial Investigation Unit (FIU). Senior Management often hires Dominion to assess FIU operations and effectiveness.

Upon completion of an FIU Assessment Dominion will deliver a comprehensive written report of findings, describing in detail and with supporting information those areas where the FIU is operating effectively and those areas where the FIU could enhance its operations. Our recommendations, once implemented, will provide meaningful contributions to the FIU and the overall BSA/AML compliance program.

All recommendations are accompanied by descriptions on how they can best be implemented and the timing and effort necessary to implement each. In addition to the written report of findings and recommendations, we provide a grid of our findings on which we will risk rate those we believe are of a critical nature and those we believe are less critical to the long term sustained success of the FIU.

Program Development

For banks ranging in asset size from $1 billion to more than $1 trillion, Dominion has assisted in building and/or enhancing Financial Investigation Units (FIUs). Implementing transaction monitoring systems, developing programs to identify and perform due diligence on high risk customers, designing monitoring programs, assisting in hiring staff, training, procedure development, SAR filing and department management – Dominion’s team has an unmatched record of success in creating and improving FIUs.

Transaction Monitoring System Optimization

Transaction monitoring software is often plagued by the same problem; identifying far too many transactions that have little to no value to an investigator. Problem is, these low value alerts, often hundreds or thousands a month, become a hulking burden on the AML compliance program. Reducing low value alerts and zeroing in on those that are likely to identify suspicious activity is an expertise of Dominion. We have implemented optimization programs that have substantially reduced alerts that do not result in a SAR, saving clients considerable time and money and enabling them to focus their efforts on those things that matter most to maintaining AML compliance.

Backlogs of Alerts and Cases

A new monitoring system, new monitoring scenarios, departures of key staff, and new expectations by regulators, are all examples of why some institutions find themselves in a situation where alert or investigation inventories grow and cannot be resolved in a timely manner.  Our team of investigators, quality control specialists and managers are without equal and so is our record of success in the area of AML staff augmentation.  Additionally, Dominion provides an option to each client: we can assist with staff augmentation on site at the client’s offices or remotely from Dominion’s offices.

Investigation Training

The Dominion investigator training program prepares staff to better detect, analyze and report suspicious activity.  We have trained hundreds of investigators from small, mid-size and some of the largest banks in the world. Our training is designed so that AML managers will see immediate improvement in the quality of alert dispositions, investigations and SARs. The training is valuable for experienced investigators as well as those new to AML. Our curriculum focuses on how to identify suspicious activity, the role of regulators and auditors in reviewing case files, and common mistakes and weaknesses that make banks prone to criticism.

High Profile and/or complex financial crime investigations

A core service Dominion offers is assisting clients with highly sensitive and complex money laundering investigations.  Examples include investigations involving alternative investment vehicles, complex layering schemes, networks of off offshore entities located in Bank Secrecy havens, ultra-high net worth individuals and, politically exposed persons.

Quality Control

Dominion is often hired to perform quality control reviews of completed AML alerts, cases, SARs, and due diligence reports.  The Dominion quality control process has a duel benefit:  1) ensuring compliance with bank policies, procedures, and regulatory expectations.  2) training analysts and investigators by providing constructive feedback and recommended approaches to rectify deficiencies.

Enforcement Action and Regulatory Response

Enforcement Actions

Dominion works with institutions responding to regulatory enforcement action or regulatory findings that if not addressed quickly and effectively, may lead to an enforcement action. Dominion understands the pressure enforcement actions put on a bank’s management team and the how the large volume of work required to correct problems needs to be planned, organized and executed.

Look Backs

Always unpleasant and always more work than imagined, Look Backs are sometimes required by regulators and law enforcement. In these cases, banks need a firm whose entire team is deeply experienced in the setup, execution and management of these complex projects. Dominion’s record of achievement in this area is among the most notable in the industry.

Project Management

Dominion has managed the industry’s largest and most complex AML development and remediation projects. We use advanced case management, quality control and productivity measurement tools so we can maintain our commitment to deadlines and budgets while ensuring our clients are thoroughly prepared for their next audit or regulatory examination.

High Risk Customer Management Programs and Enhanced Due Diligence

A core service Dominion provides is developing and implementing programs to identify existing high-risk customers and risk rate new customers at account opening. Dominion has developed proprietary methods and algorithms to mine vast quantities of demographic and transactional data for the purpose of identifying customers that truly present a higher than normal BSA/AML risk.

Additionally, Dominion has developed a comprehensive Enhanced Due Diligence process and procedures specific to each and every customer type typically considered high risk by banking regulators.

Case Management and Management Information Reporting

Automating workflow and keeping electronic records organized and in one place is a necessity for a successful AML program. Case management software is needed to ensure AML operations operate effectively. In addition, case management holds the key to management information reporting and tracking of key performance metrics. Dominion wrote the business requirements for an industry leading case management system and has also developed and implemented case management solutions for dozens of financial institutions. Being steeped in AML operations, we also understand what information and reports management needs to ensure a Financial Intelligence Unit (FIU) is working properly and risks are being adequately mitigated.