Financial crime advisory and consulting

We provide a comprehensive set of services, resources, and continuing guidance tailored to meet the needs and requirements of your financial services firm attain and maintain industry regulatory requirements and best practices.

Our key services include:

Compliance AML Program Re-design and Implementation

Whether as a result of an enforcement action or as a self-initiated project, Synist can work with you to evaluate, redesign and implement part or all of your compliance program. Our experienced consultants can advise financial institutions on current industry standards and best practices in Financial Crime compliance in the following areas: program governance, policies and procedures, risk assessments, name screening, KYC transaction monitoring, and case management systems and processes, customer risk scoring models, staffing capacity plans, systems integration and implementation, and transaction monitoring system tuning and optimization.

New customer onboarding

We offer end-to-end management of KYC processes for new customers and products. This includes document gathering and validation based on policy requirements and the sourcing and interpretation of structured and unstructured data from both internal and trusted external sources. Aggregating this information to a single client view accelerates risk assessment and verification.

Due diligence

Our rules-based identification, aggregation and automation of customer information across business lines, legal entities, and jurisdictions streamlines the process and is designed to accurately address the data requirements for ultimate beneficial owners (UBOs).

Customer information refresh and remediation

Our end-to-end management of KYC processes for existing customers is based on renewal cycles and customer trigger events. The KYC process is enabled by workflow management covering tasks, automatic communications, integration of screening, Customer Due Diligence (CDD), Enhanced Due Diligence (EDD) and risk rating, and alignment with a quality control framework.

Backlog, Lookback and Key Person Staffing Support

Synist provides experienced staffing to financial institutions to assist in the clearance of backlogs or to conduct lookbacks in the following areas: customer due diligence (CDD) reviews, enhanced due diligence (EDD) reviews, name screening alerts, OFAC alerts, transaction monitoring alerts, case investigations and suspicious activity reports (SAR), trade surveillance alerts, and fraud alerts. We also provide our clients with “key person” staffing. Our experienced consultants can stand in to cover key positions in compliance departments on an interim basis.

Customer Risk Scoring Model Design, Testing, Tuning, and Implementation

It is critical to evaluate the AML risk that each customer represents to the financial institution. Our team can evaluate your current state risk scoring model and advise how to enhance their customer risk scoring. Alternatively, we can design entirely new risk scoring models that are tailored to your AML program. We will work with you to test, tune and implement the risk scoring model.

Gap Assessment

Whether due to regulatory intervention or as a self-initiated project, Synist can assess and evaluate your AML Compliance program to check whether it meets industry best practices. It is important to periodically conduct gap assessments in order to keep up with current industry AML standards and best practices. Our consultants have considerable experience, knowledge of industry standards and expertise in all areas of AML Compliance, and are well-equipped to complete a gap assessment for your firm.

Regulatory Response

We have successfully assisted financial institutions in connection with AML regulatory-related inquiries and responses. Our collective and unique insights, coupled with industry knowledge and regulatory know-how, help our clients meet regulatory expectations and resolve AML deficiencies in the face of regulatory scrutiny.

Risk Assessment

An integral component of a robust Compliance program is the completion of an annual risk assessment. Financial institutions should conduct tailored enterprise-wide risk assessments to evaluate the inherent risk of the various businesses at their firm against their control environment. Once residual risks are identified it is important for AML Compliance departments to enhance their AML programs to address the risk. Bates has experienced consultants who specialize in risk assessments from the smallest to the largest and most complex financial institutions.

Transaction Monitoring Business As Usual Investigations

Synist also places AML investigators and project managers at our financial institution clients to assist with BAU reviews and AML investigations involving negative news, fraud, regulatory subpoenas, transaction monitoring and case investigations in order to reduce or eliminate backlogs. Our experienced investigators assist with all aspects of the investigation, including reviewing transaction monitoring alerts, producing an investigation narrative supported by evidentiary documentation and ultimately drafting and filing Suspicious Activity Reports (SARs), when necessary.

Transaction Monitoring Look-Back Investigations

Whether due to regulatory intervention or self-initiated assessment, a look-back review of clients and transactions may be necessary to address potential concerns regarding transaction activity. Within days, Bates can and has placed a significant number of AML investigators, together with AML project managers, at our financial institution clients to assist with AML investigations involving negative news, fraud, regulatory subpoenas, reviews of transaction monitoring alerts and case investigations. Our experienced AML investigators understand the intricacies of a look-back review while gaining information to clear alerts, , producing case investigation narratives supported by evidentiary documentation and, if necessary, ultimately drafting and filing Suspicious Activity Reports (SARs).

Model Validation

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We help clients avoid the trap into which many institutions fall – not ensuring their software system is accurately capturing and analyzing AML data. Your critical activities – transaction monitoring, account profiling, customer risk rating, Currency Transaction (CTR) and Suspicious Activity (SAR) reporting – can all be adversely impacted; it’s a major risk. With our comprehensive knowledge of the systems and platforms utilized in the industry, we’ll perform effective software validation, model calibration and optimization, or help you with new systems. You avoid the noise and achieve optimal output and efficiencies, as we support you all the way.

General / Program Consulting

When it comes to AML consulting, we are here to help. We’re ready to step in as your Compliance Manager and protect your institution from regulatory criticism. Our team provide high level support in helping to update programs, implement remediation and provide staffing assessments and augmentation.

Training

A large number of companies in Luxembourg and abroad, including banks, credit institutions, PSF, management companies, accounting firms, external auditors, solicitors, real estate, notaries and investment funds, must ensure that all staff receive adequate ongoing training.
The main objective of that training is to enable employees to deal with the daily requirements of their professional duties by equipping them with the right tools to identify any critical issues that may arise, and develop the right practices to prevent such issues arising in the first place, wherever possible.

Services