Guidepost Solutions was engaged by the bank to conduct a review of its anti-money laundering and global sanctions policies and procedures. This engagement involved testing the sanctions filtering software and tools to identify vulnerabilities and assess its level of compliance.
We reviewed and assessed controls for correspondent banking and U.S. dollar clearing activity, including a detailed assessment of its due diligence and enhanced due diligence processes and procedures, governance structures, customer risk assessment methodology, Know Your Customer, management information and de-risking initiatives. We provided recommendations to address control gaps and deficiencies and work closely with management to raise standards to a level acceptable to U.S. regulators. We also performed an initial assessment of its transaction monitoring scenarios and thresholds for cross border and correspondent banking activity; the scope of completeness of its annual global OFAC risk assessment; and a review of its ability to comply with payment transparency requirements, travel rule and wire origination rules. During the course of the engagement, the Guidepost team conducted multiple site visits in the United States, Europe, Africa, and Asia.