Anti-Money Laundering
Home > Expertise > Compliance

Anti-Money Laundering

Representative Engagements

Money laundering and terrorist financing activities are receiving increased attention from governments, banking authorities, and regulatory authorities around the globe. These risks remain one of the most pressing compliance risks facing financial services institutions today. These risks are compounded by the fact that money launderers and terrorist financiers continue to change their behavior in an effort to evade ever-improving controls.



Banks and other financial services institutions play a vital role in discouraging criminals and terrorists, given their direct involvement in the flow of funds.  As a result, global financial services industry participants are required to comply with domestic - and frequently multi-jurisdictional - regulatory requirements aimed at identifying and reporting suspicious and unusual customer and transaction activities.  These regulations are set out, for example, in the Banking Secrecy Act and the U.S. Patriot Act for the U.S. and the Joint Money Laundering Steering Group Directives from the European Union.  

Promontory’s Anti-Money Laundering and Counter-Terrorism Financing practice operates globally, ensuring that the full team is kept abreast of developments throughout the world and bringing best practices and news of recent events to our clients. As a result, Promontory is especially helpful to firms operating in multiple jurisdictions and to those headquartered outside major financial centers, all of which need to meet requirements that may differ from those of their home country. Our clients include community, regional, and global banks, securities firms, asset managers, commodity brokers, insurance companies and others based in North America, Central and South America, Europe, the Middle East, Africa and Asia-Pacific. Promontory is able to respond appropriately, whether a client is facing a severe regulatory challenge that needs addressing within a compressed time frame, a client requires assistance in this area as part of a broader review or investigation, or a client merely wants assurance that its existing programs appropriately incorporate regulatory and market expectations effectively and efficiently.    

The strength of our Anti-Money Laundering and Counter-Terrorism Financing practice comes from the depth of experience and expertise Promontory professionals have gained from their roles in government, the financial services industry, regulatory agencies and law enforcement agencies.   Our professionals have drafted laws and regulations, advised regulators, worked with governments, and supported clients in their fight against criminals and terrorists.  

Our work with numerous financial institutions affords us a broad view of industry practices and issues; our work with regulators provides us with insights into changing expectations of these programs.   

Promontory has advised clients across a broad spectrum of Anti-Money Laundering and Counter Terrorist Finance needs, including: 

  • Assessment of existing anti-money laundering and counterterrorist finance risk management programs and recommendations for enhancement 
  • Design and implementation of comprehensive risk management programs or individual program components such as AML compliance risk assessments, policies and procedures, monitoring and surveillance capabilities, and management reporting 
  • Identification of legal and regulatory requirements within and across businesses and within the jurisdictions in which they operate  
  • Development of appropriate, risk-based customer assessment, selection, documentation, risk refresh and related transaction monitoring practices 
  • Performance of gap analyses and identification of remediation recommendations resulting from regulatory changes  
  • Design of transaction monitoring scenarios, identification of unusual and suspicious activities, and filing of suspicious transaction reports 
  • Advising clients on planning and executing remediation activities, driven by their own or a regulator’s identification of an issue; 
  • Running large-volume, historic transaction look-back reviews to quantify the extent of previously weak risk management programs 
  • Assessing the efficacy and efficiency of transaction monitoring systems
  • Reviewing the effectiveness of quality assurance, compliance testing and monitoring and independent testing processes
  • Designing and delivering training, in person or via e-learning, for boards, executive management and all employees 

Representative Engagements

  • Performed a regulatory compliance review and restructuring of one of the world’s largest nonbank financial services providers, with an in-depth focus in the areas of anti-money laundering, the Bank Secrecy Act, and “Know Your Customer” requirements.  The review assisted the institution in avoiding onerous enforcement penalties as remediation actions were under way. 
  • Worked alongside a client to perform a look-back review and a control and infrastructure review related to US Bank Secrecy Act requirements as required by multiple consent orders. The reviews covered the client’s operations in the Caribbean. Our report findings were completed within the prescribed time frame and accepted by the FDIC, the lead regulator, which lifted the orders within 60 days of receipt of our report. 
  • We have performed comprehensive evaluations of AML programs and related outputs for numerous clients. Key components included risk assessment, policies and procedures, client due diligence, transaction reporting, filing of suspicious activity reports with relevant regulatory agencies, and training.  In addition, Promontory assisted with the implementation of emerging recommendations as requested by the client. 
  • Assisted a client with an AML-related enforcement action through which additional compliance risk management program weaknesses were identified.  The remediation of the AML weaknesses was achieved alongside a complete overhaul of the client’s compliance department. This included a Promontory professional temporarily assuming the role of Chief Compliance Officer, a revision of all compliance policies and procedures, and a redesign of the surveillance and monitoring program.  This work was performed under significant time pressure because the client intended to acquire another financial institution; this which was allowed only once the AML concerns and subsequently identified broader issues were resolved.