Financial institutions are facing a wave of regulatory scrutiny. This trend is not showing any sign of slowing down. In fact, recent government inquires have uncovered money laundering and sanctions violations at several major financial institutions. As a result, these companies have been assessed billions of dollars in fines and subjected to look-back investigations to assess further breaches of anti-money laundering and sanctions requirements and programs. As part of government inquiries, financial institutions are often required to perform extensive reviews of transactions and communicate any suspicious activities to their regulators with accuracy and speed. To achieve this and avoid future fines, financial institutions should enlist subject matter advisors, add resources and utilize advanced analytics tools to perform the investigations.

Navigating through the regulatory environment

Our professionals at EY use our experience and demonstrated track record of success to help our clients adapt to this highly regulated environment. Our dedicated Global AML team has extensive knowledge and experience with all types of payments, including banknotes, wire activity, remote deposit capture and electronic payments. We can assist with monitoring strategies, pouch reviews, detailed transaction reviews, financial investigations and Suspicious Activity Report (SAR) preparation. Our leading-edge technologies, paired with our industry knowledge, allow us to assist our clients in a cost effective way when they are subject to government scrutiny and inquiries.

Our teams include certified anti-money laundering specialists (CAMS), former law enforcement officers, former regulators, CPAs, CFEs and forensic accountants. We can help you with:

• Comprehensive AML and sanctions investigations

• Historical transaction reviews in response to regulatory inquiries

• Know Your Customer (KYC) due diligence and enhanced due diligence of current and prospective customers

• Data/trend analysis of transactional activities

• Recovery and extraction of forensic data

• Quality reviews of completed investigations and filed SARs

• Post-regulatory action requirements, such as remediating non-compliant KYC and transaction files

Financial crimes investigations

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A history of results

EY has invested in leading technology, proven methodologies and execution strategies to target effort and reduce overall cost. We deploy these strategies successfully on behalf of our clients and the regulatory bodies monitoring the AML marketplace. EY was recognized as “#1 for Best Consultancy Overall” in the October 2015 issue of Operational Risk & Regulation: ”[EY] takes an enterprise-wide approach to support firms as they enhance their systems and control frameworks or carry out regulatory remediation programs.”

Here are some examples of how we have successfully assisted our clients:

AML and sanctions support

EY (its member firms) was engaged by a large foreign-based financial institution

following the largest ever US settlement resulting from violations of economic sanctions. EY supported the institution, which was under the supervision of an Independent Monitor, by helping them bolster and improve multiple aspects of its AML and Sanctions compliance program. EY worked closely with the institution’s senior leadership to reconfigure its US- based AML transaction monitoring department. This included conducting investigations into pending U.S. dollar transactions for sanctions concerns, monitoring client referential files for potential sanctions concerns, and delivering training on the Office of Foreign Assets Control (OFAC) and other sanctions. Additionally, EY built a database to manage the SAR process from referral to filing.

SAR look-back review

EY performed a look-back review of a global financial institution's SAR filings, against a quality criteria and when necessary assisted in drafting corrections/amendments. The look-back review was in response to a regulator consent order entered into by the financial institution and the Office of the Comptroller of the Currency (OCC). The consent order committed the financial institution to address certain deficiencies in its Bank Secrecy Act (BSA) and AML compliance program.

AML Investigation

EY conducted a full scale investigation of a client subsidiary bank's AML and OFAC compliance program. The team analyzed targeted emails of the bank subsidiary employees, process documentation,

contracts and general ledger details, which primarily involved money transfer business products, to address the bank's BSA and AML compliance deficiencies. EY collected and preserved large scale data for priority custodians, analyzed key general ledger accounts, and performed a detailed account analysis of customers identified by regulators.

Transaction review and program assessment

EY performed a transaction review and compliance program assessment for a foreign financial institution as a result of a regulatory Notice of Findings (NOF) document. EY conducted a review of transaction activity, customer files, computer records and suspicious transaction reports related to activity with OFAC and sanctions implications. EY performed a review of the institution’s compliance program including AML policies

and procedures and related to OFAC and sanctions screening processes.

AML and economic sanctions investigations

A large Europe-based holding company with operations in commercial banking, investment banking and other financial-related services engaged EY to perform a comprehensive, multiyear historical transaction review. The engagement required remedial reviews of more than 30 million transactions potentially in violation of OFAC regulations and included transactions involving 27 countries. Our team deployed a risk-based approach to reduce the total reviewed to 140,000 transactions. We performed a detailed transaction review involving data selection and collection, completeness checks, filtering, screening, in-depth analysis and quality reviews.

KYC review and remediation

EY assisted one of the world’s largest casino operators to perform enhanced due diligence reviews on a selection of new and existing high-risk patrons from across all properties. EY screened the client’s patrons through watch lists, sanctions/embargos databases, politically-exposed person (PEP) and state-owned entity (SOE) listings, adverse media search results, and criminal and civil litigation records. EY reviewed gaming records of play and payments to the casino, patron SAR history and CTR records. EY employed a global team to perform due diligence in local languages. The reviews resulted in KYC reports that assisted the casino in assessing the risk of maintaining its relationships with select patrons.

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Global investigative experience

Countries where investigations or compliance work has been performed

We have dedicated professionals providing a full suite of investigative work related to AML and sanctions programs. Our professionals have performed many successful engagements on a global scale at some of the world’s largest financial institutions (banks and non-banks). Our global presence consists of the following:

► 152 locations in 73 countries

► 194 partners

► 4,200 professionals, including over 1,700 in emerging markets

► Capability to deploy resources in any geographic area on short notice

Contacts:

Walid Raad Partner +1 212 773 0956 walid.raad@ey.com

Arpi Lal Senior Manager +1 212 773 3038 arpi.lal@ey.com

Chris Sercy Principal +1 212 773 3916 chris.sercy@ey.com

Brad Massam Partner +1 212 773 5620

bradley.massam@ey.com

EY | Assurance | Tax | Transactions | Advisory

About EY

EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities.

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This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax or other professional advice. Please refer to your advisors for specific advice.

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