AML Compliance

IGI provides investigative support and advice to help ensure clients’ compliance with anti-money laundering (AML) rules and regulations, including the Bank Secrecy Act (BSA), the USA PATRIOT Act, the Money Laundering Suppression Act, and the Intelligence Reform & Terrorism Prevention Act of 2004, as well as reporting regulations of the Treasury Department’s Office of Foreign Assets Control (OFAC) and FinCEN (the Financial Crimes Enforcement Network).

IGI’s AML services focus on preemptive and prescriptive advice designed to mitigate risks and prevent violations before they occur, including thorough due diligence, review of existing internal controls, and the design and implementation of suspicious financial transaction monitoring systems to identify and flag potential money-laundering, tax evasion, and terrorism financing-related transactions.

IGI provides extended and enhanced due diligence to supplement bank and brokerage firm Know Your Customer processes for onboarding politically exposed persons (PEPs) and other potential high-risk customers.

We have broad experience working on behalf of U.S. banks to conduct AML risk assessments and compliance reviews of their existing and prospective foreign correspondent banking relationships.  We also have consulted with and conducted compliance reviews for foreign financial institutions who are seeking to gain or maintain relationships with U.S.banks and access to the U.S. financial system.

  • A U.S. bank with embassy and foreign government banking business was embroiled in a scandal related to money laundering for heads of state and officials of foreign governments. At the time IGI was brought into the case, U.S. government agencies and the bank’s auditors had already conducted investigations. IGI was retained by the bank’s outside counsel to independently review the scope of the findings of the previous probes and to identify and investigate additional concerns.
  • A U.S. financial services company retained IGI to provide due diligence with a focus on money laundering concerns related to a large book of foreign correspondent-banking relationships the client was acquiring from another bank. Our due diligence effort examined more than 200 banks in 35 countries.
  • A prominent New York financial institution retained IGI to investigate the background and reputation of their potential customer, a prominent family in the business community of a Latin American country, with a focus on the sources of the family’s assets including the possible influence of a former government official thought to be related to the family. IGI’s investigation, including in-country inquiries, determined that the government official in question was not related to the client’s potential customers, and further research and inquiries helped the institution more confidently assess the reputational risk of their new customer relationship.