GRACE - AML for Anti-Money Laundering

Banking Security Act / Anti-Money Laundering Act that is part of the US PATRIOT Act 2001 expects financial institutions to set up policies and procedures for anti-money laundering, reporting and has record keeping obligations. High profile cases like HSBC where failures to set up and monitor the Anti-Money Laundering processes have resulted in huge fines. Investment Advisors including Broker/Dealers, Hedge funds, Custodians, Fund administrators, Private Banking accounts all need to build in processes for Anti-Money laundering for investor due diligence as well as transaction monitoring.

FINRA’s rule 3310, FINRA Updated template, 2010 Annual Examination Priorities Letter ,SEC’s whistle blower incentives all point to increased scrutiny of the AML processes within the organizations.

It means that financial institutions must establish a comprehensive and rugged anti-money laundering program that should include:

  • Internal Policies, Procedures and controls for detection and prevention of terrorist activity
  • Designation of Compliance officer who will be responsible for the implementation and continued efficacy of the program
  • Maintain an on-going employee training program
  • Have an independent audit program to measure the effectiveness of the policy implementation including the
    • Know Your Customer Procedures (KYC)
    • Suspicious Activity Reports (SARs)
    • Information sharing with FinCen and safe harbor procedures

GRACE-AML with its SaaS (software as a service) model helps you put quickly together a good risk management program for all risks related to the process of Anti-Money Laundering verification, monitoring processes and remedial action so as to ensure compliance to the program to be prepared for regulatory audits and avoid penalties for non-compliance.

GRACE-AML offers helps you put together your internal processes in a central place and provides you web based access to the information. It provides you the infrastructure for you to build:

Be a central repository for all Anti-money laundering information for the organization

Be able to verify that all Anti-money laundering processes work in a well

Be ready for regulatory audits and produce proof of process

Be operationally efficient in the process by consolidation of all information centrally. Having them spread out in multiple excel files, documents and paper trails makes the process inefficient and labor intensive to retrieve and produce it for audit

Help senior management be confident that they are conforming to their regulatory provisions

Institutionalize the BSA/AML process

Own the knowledge in the enterprise and not lose it when key people leave
Policies & Procedures

Policies and procedures repository where you can add, update, review and release policies, procedures, disclosures
Version histories and provides access to the latest policy and procedure to the organization

Assessments & Audits

Calendar for BSA/AML assessments & audits
Audit and assessment checklists
Manage the assessment and audit planning and review process
Monitor the progress of assessment and audit execution and collect deliverables when ready through project and task reporting
Record findings,do impact analysis, identify the risks from the findings and establish a process for risk mitigation
Monitor the tasks and costs of the risk mitigation process till closure
Task reporting of mitigation tasks, and project reporting to monitor the progress of mitigation projects
Mechanism for you to build standardized checklists for audits and assessments that can be reused for each subsequent audit and can be changed to suit the particular audit
Alerts on due dates, over dues and late dues in activities and tasks

Investor Due Diligence - KYC

Perform due diligence through standardized checklists on all new investors / customers and periodic due diligence on existing customer information
Maintain an investor negative watchlist
Provide processes for recording of due diligence information and review of the due diligence findings

Provide alerts for periodic due diligence assessments, conduct these assessments in a standard way, review findings and record risks if any
Builds a repository of all the due diligence information collected
Set up processes that monitor transactions for Anti-Money laundering and monitor them through the Internal control monitoring process
Build a history of all information on customer so it can be retrieved any time

Internal Controls Management

Functions for internal control definitions
Process for monitoring the internal control through test definitions, periodicity of testing and reporting
Process for test issue reporting and review to bring to light the issues and risks early
Process to create mitigation strategies for the issues and risks identified and monitor the mitigation progress
Information on all issues and trends in each internal control

Loss Monitoring

Record of losses in operations and loss classification
A method to monitor loss mitigation / control

Interface with operational reports

An interface to bring in BSA/AML operational reports including Suspicious Activity reports (SARs) for FinCen, Current Transaction Reports (CTRs) and others, process for review and risk recording from there and escalate them where necessary

The Dashboard

The powerful dashboard brings together the umbrella of all information related to risk
Allows deep drill down on all information across due diligence, assessments and audits, losses, internal controls and tasks associated with management of the risk and reports on mitigation task status
Slice and dice of information to bring different trends to view
Queries and Reports that can be exported to Excel / PDF formats