Financial Institutions
Monitorship
As the Sanctions Team Lead, Mr. Riley has been assisting a European headquartered global bank with the review and testing of the Office of Foreign Assets Control (OFAC) compliance policies and procedures. The scope of this review consisted of payment- based transactions, trade finance, and other financial product transactions, as well as “Know Your Customer” procedures.
Independent Advisor
As part of pre-settlement remediation, Guidepost assisted a major European banking group assess their compliance with U.S. banking and sanctions laws. This engagement involved dozens of trips to the banking group branches throughout the world and the preparation of compliance assessment reports to external counsel.
Independent External Provider
Guidepost was engaged in a multi-year monitoring engagement of a European banking group as part of their settlement with U.S. authorities. This engagement focused on the banking group’s compliance with OFAC requirements and involved extension on site reviews in several European countries.
Virtual Currency Providers
Bill has led several consulting engagements assisting both early stage and mature virtual currency service providers to build, assess, test, and enhance their BSA/AML and Sanctions compliance frameworks. This support included annual regulatory audit requirements, risk assessment development, AML and Sanctions tool testing and calibration, and creation and implementation of policies and procedures.
I-9 Compliance
Mr. Riley has assisted several major corporations with assessing and enhancing their I-9 compliance programs. These engagements involved both proactive assessments as well as reactive assistance when clients were being audited or investigated by federal regulators. Mr. Riley’s 31 years of experience in I-9 compliance and fraudulent document/identity detection have assisted clients with administrative, civil and criminal defense. Guidepost has development a significant practice in this areas and has assisted employers with high-volume I-9 reviews as well as difficult logistical engagements where our team members traveled throughout the U.S. to assist with remediation efforts.
Major Restaurant Chain
Guidepost was engaged to assist a major restaurant chain in reviewing their I-9 compliance program and to audit their completed I-9 forms. Guidepost assisted reviewing over 50,000 I-9 forms to identify both systematic issues with their I-9 tool and procedures as well as individual issues with managers repeatedly making errors on the I-9 forms. Guidepost added additional value by identifying several fraud scenarios in which workers were presenting fraudulent documents or misusing identity information of U.S. Citizens.
Agricultural Client
Guidepost subject matters experts assisted a client on a multi-year engagement by assisting with their criminal defense, revamping their I-9 compliance program, and remediation employees who had presented fraudulent documents. Guidepost assisted this client by developing and delivering a comprehensive I-9 training program which included fraudulent document training, identity theft indications and the deployment of additional tools to prevent unauthorized workers from gaining employment through fraud.
Major Logistics and Transportation Company
One of the unique aspects to Guidepost’s I-9 compliance program is our ability to get “boots on the ground” anywhere in the U.S. to assist employers with I-9 and immigration compliance issues. Guidepost assisted this client by working 24×7 shifts meeting employees in more than 100 unique locations throughout the U.S. in order to prepare or correct their I-9 forms.
Major Food Processing Company
Guidepost assisted a major food processing company by conducting third party I-9 compliance audits and document/identity fraud assessments of their contractors. As noted by ICE’s IMAGE program, one of their recommended best practices is to “Ensure that contractors and/or subcontractors establish procedures to comply with employment eligibility verification requirements. Encourage contractors and/or subcontractors to incorporate IMAGE Best Practices and when practicable incorporate the use of E-Verify in subcontractor agreements.”
International Student (SEVIS) Compliance
Mr. Riley assisted a major U.S. university with conducting an independent assessment of their SEVIS international student compliance program. This review included reviewing student files to ensure compliance with the DHS and DOS requirements for the school and for the students. The review also included recommendations for enhancements to the program as well as best practices to ensure continued compliance.
