Anti-Money Laundering
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Anti-Money Laundering

Representative Engagements

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.


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.

We are able to respond appropriately, whether a client is facing a severe regulatory challenge that needs addressing within a compressed time frame, requires assistance in this area as part of a broader review or investigation, or 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 Services

Promontory advises clients across a broad spectrum of anti-money laundering and counter terrorist finance needs, including:

  • AML & Sanctions Compliance Program Review
    We enhance compliance programs by developing governance structures, compliance risk reporting, risk assessments, policies and procedures, monitoring, and testing mechanisms
  • Transaction Monitoring Optimization
    We evaluate scenarios and rules against the institution’s risk profile, industry practice, and regulatory expectations
  • AML Transaction Overflow
    Our overflow capacity facility can handle all excess case work, from alert resolution to case investigation to SAR preparation
  • Staff Augmentation
    Our team consists of seasoned AML professionals, many of them attorneys and CAMS-certified who can assist institutions on-site in several capacities
  • Transaction Reviews (“Look Backs”)
    We conduct transaction reviews to the highest regulatory standards
  • “Know Your Customer” Remediation 
    Assisting institutions with KYC remediation of retail, corporate and correspondent banking customers
  • Risk-Based Training 
    We provide customized training for the bank’s board of directors, management, and compliance staff

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.