FinCEN Files Assessment — Customer Due Diligence Review
European multilateral development bank | Risk & regulation | Supranational
The challenge: Following the publication of the Financial Crimes Enforcement Network Files — a leak of suspicious activity reports filed by major global banks — a European multilateral development bank needed to assess its exposure to the entities, individuals and banks identified in the reporting, and evaluate whether its Anti-Money Laundering and Counter Financing of Terrorism policies could be enhanced in response.
What New Link Consulting did: New Link Consulting investigated the bank's potential exposure to the Financial Crimes Enforcement Network Files, assessed the adequacy of its existing Anti-Money Laundering and Counter Financing of Terrorism policies and procedures — including those relating to Suspicious Activity Reports — and developed a methodology for assessing similar future disclosures efficiently.
The outcome: A clear assessment of the bank's exposure, recommendations for enhancing Anti-Money Laundering and Counter Financing of Terrorism policies and procedures, and a reusable methodology for responding to future Anti-Money Laundering-related disclosures.
