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Description
Before a BSA/AML and OFAC sanctions program gets built, rebuilt, or remediated, someone has to establish what the institution actually needs: its products, rails, and partners; its regulatory posture; and the gap between the program it has and the one examiners will expect to find. This workshop is that step.
It's a structured, one- to two-day working session with your leadership, BSA Officer, and the product, operations, and technology owners who will live with the outcome. We work through the program against the standard examiners actually apply, reasonably designed, risk-based, documented, and defensible under 31 CFR Chapter X and the FFIEC BSA/AML Examination Manual, and we leave with a plan that fits your institution rather than a template.
Who it's for
Institutions that need a program, not a policy binder: a fintech or payments company preparing for sponsor-bank onboarding or state MSB licensing; a BaaS sponsor bank standing up financial crimes oversight of its partner portfolio; or an institution whose existing program has drawn an MRA or enforcement action and needs a clear-eyed view of what a rebuild involves before committing to one.
How it works
Before the session. A focused document request and a short pre-read: existing policies and risk assessments, product and partner inventories, recent examination or audit findings, and any open regulatory commitments.
In the room. Facilitated review of the program across the five pillars: risk assessment, governance and controls, BSA Officer and Board oversight, training, and independent testing, plus the areas that separate a sponsor bank or payments company from a traditional institution: partner due diligence and oversight, transaction monitoring and sanctions screening across ACH, wire, and card rails, SAR governance, and Travel Rule and funds transfer recordkeeping. The goal is a shared, unvarnished picture of where the program stands and what examiners will see.
Afterward. A written strategic assessment and roadmap: prioritized gaps and their regulatory significance; the target program design at the level of policies, controls, staffing, and technology; sequencing and dependencies; and a scoped, priced proposal for the build or remediation phases that follow. Delivered within 5 business days of the session.
Description
Before a BSA/AML and OFAC sanctions program gets built, rebuilt, or remediated, someone has to establish what the institution actually needs: its products, rails, and partners; its regulatory posture; and the gap between the program it has and the one examiners will expect to find. This workshop is that step.
It's a structured, one- to two-day working session with your leadership, BSA Officer, and the product, operations, and technology owners who will live with the outcome. We work through the program against the standard examiners actually apply, reasonably designed, risk-based, documented, and defensible under 31 CFR Chapter X and the FFIEC BSA/AML Examination Manual, and we leave with a plan that fits your institution rather than a template.
Who it's for
Institutions that need a program, not a policy binder: a fintech or payments company preparing for sponsor-bank onboarding or state MSB licensing; a BaaS sponsor bank standing up financial crimes oversight of its partner portfolio; or an institution whose existing program has drawn an MRA or enforcement action and needs a clear-eyed view of what a rebuild involves before committing to one.
How it works
Before the session. A focused document request and a short pre-read: existing policies and risk assessments, product and partner inventories, recent examination or audit findings, and any open regulatory commitments.
In the room. Facilitated review of the program across the five pillars: risk assessment, governance and controls, BSA Officer and Board oversight, training, and independent testing, plus the areas that separate a sponsor bank or payments company from a traditional institution: partner due diligence and oversight, transaction monitoring and sanctions screening across ACH, wire, and card rails, SAR governance, and Travel Rule and funds transfer recordkeeping. The goal is a shared, unvarnished picture of where the program stands and what examiners will see.
Afterward. A written strategic assessment and roadmap: prioritized gaps and their regulatory significance; the target program design at the level of policies, controls, staffing, and technology; sequencing and dependencies; and a scoped, priced proposal for the build or remediation phases that follow. Delivered within 5 business days of the session.