Policies and Procedures

Aperilex develops the various components required for a comprehensive and cohesive BSA/AML program designed to improve risk mitigation and internal controls. Our focus includes:

  • Risk assessment within products, services, entities and geographic locations
  • Clearly documented internal controls for continual adherence to regulatory requirements
  • Customer identification programs containing documentary and non-documentary methods
  • Client on-boarding and Know Your Customer (KYC) Programs
  • Due diligence programs based on customer risk and the bank's overall risk assessment
  • OFAC screening processes for new and existing customers
  • Timely detection and reporting of suspicious activity
  • Section 314 Information Sharing Program
  • Record keeping and document retention
  • Internal testing to complement independent audits
  • Enterprise-wide process for communicating and reporting compliance issues and initiatives

Financial Intelligence Unit (FIU) Optimization

FIU Optimization counterbalances the cost constraints and limited resources often faced by BSA Officers. Aperilex's FIU re-engineering solutions includes:

  • Detailed process flow charts
  • Investigation report templates
  • A central repository of all BSA/AML material for employee reference
  • Investigative techniques for detecting red flags specific to products and entities
  • Account profiling for improved AML investigations
  • Requirements and guidelines for conducting due diligence
  • Sampling methodology for reviewing accounts and transactions

Training Programs

A proper training program is vital to successfully maintaining a BSA/AML program and promoting an enterprise wide culture of compliance. That's why Aperilex offers customized training programs for:

  • New employees as part of their overall orientation program
  • Role- and responsibility-specific employees
  • BSA Officers, covering industry developments, emerging risk and regulatory changes
  • Boards of Directors, covering regulatory requirements and risks posed to the bank
  • AML issues and trends critical to business lines and departments

Quality Control

A robust quality control program identifies compliance issues before they become entrenched into daily operations and undermine an effective BSA/AML program. Aperilex can satisfy quality controls needs by performing the following:

  • Validation and assignment of appropriate customer risk rating
  • Assessment and modification of transaction monitoring scenarios
  • Inspection of investigation case files
  • Independent audits

Did you know?

FinCen issued an “advanced notice of proposed rulemaking” on customer due diligence at US financial institutions. Among the measures, the proposed rule would require institutions to identify beneficial owners of accounts down to a 20% ownership stake during initial due diligence.

Contact Aperilex to discuss how we can help establish CDD standards for understanding ownership structures and documenting beneficial ownership and controlling parties.

Contact Aperilex