Systematic and Efficient AML Look-Back Reviews
An occasional remediation effort resulting from a Bank Secrecy Act and anti-money-laundering (BSA/AML) regulatory exam requires a bank to perform extensive reviews of customer accounts and transactions over a defined historical time period. A look back review could be required due to lapses in monitoring and/or investigative controls, missing data, poorly calibrated monitoring rules or issues with high risk customer identification or monitoring. Frequently, these mandated look-backs must be performed by an independent third party. But even when third-party involvement is not required, AML look-backs can present significant challenges.
Not only must a bank’s financial intelligence unit (FIU) find ways to allocate necessary resources, they often times struggle to pull data and adapt existing transaction-monitoring systems to comply with the specific look-back parameters or scope.
How Crowe Horwath LLP Can Help
Crowe combines extensive look-back expertise with a proven and defined methodology and sophisticated technological solutions to help banks comply with AML look-back requirements. The Crowe methodology encompasses four phases:
- Plan and design – Developing the project charter and written plan per the defined scope and outlining the agreed-upon review processes. This is a key activity to gain consensus between the bank, their regulator(s) and if applicable the independent third party prior to proceeding and expending effort on subsequent phases.
- Detect – Acquiring and validating data, generating the in-scope look-back suspicious activity alerts from our repository of detection scenarios, and consolidating alerts into customer-level cases.
- Execute – Disposition cases of alerts and/or investigations, performing quality reviews, and developing suspicious activity report recommendations.
- Report – Providing detailed analysis and communication of the look-back results.
Specialized Technology for More Efficient Look-Backs
Crowe AML specialists use proprietary technology such as the Crowe Activity Review System®. The CARS® solution is a workflow-enabled tool that helps manage cases, alert dispositions, investigations, and quality reviews with greater efficiency, narrative generation, and documentation, providing a fully auditable work trail.
For those cases that do not require third-party reviews or outsourced investigations, Crowe can provide support for any or all of the four phases by using techniques and providing quality reviews and/or technology, such as CARS that can be adapted to support any of the various look-back processes banks might employ.