Our Staffing Augmentation Service will provide your institution thoroughly vetted and qualified staff. The staff that we provide specializes in anti-money laundering (AML) compliance and ranges from case analysts to clear alerts to technical experts who know your system to anything in between with our company’s expertise supporting them.
In the first quarter of 2019, AML-ology conducted their second AML Staffing Trends Survey. The participants were asked to indicate the number of full-time and part-time case analysts (CA’s) across their BSA (Bank Secrecy Act/transaction monitoring), OFAC (Office of Foreign Assets Control/sanctions screening), and KYC (know your customer functions). Comparing the results from the 2019 survey to their first AML Staffing Trends Survey conducted in 2016, the number of full time CA’s dedicated to BSA/OFAC/KYC declined fairly significantly from 2016 to 2018, while the number of part-time CA’s assigned to the same three programs increased. As an example of this, ARC Risk and Compliance was able to assist a large foreign banking organization (FBO) in New York City re-do their KYC documentation by hiring our staff for a temporary project to re-paper their KYC files. We were able to help the client by completing the tedious project on time and under budget. In fact, our client shared the positive feedback they received from their examiner after the project was reviewed.
The 2019 AML-ology Survey continued by asking participants if they had an adequately staffed BSA/AML/OFAC program, which is important for an institution to have a successful AML program. Consequently, 46% of participants reported that their institutions were inadequately staffed. When an institution is inadequately staffed, a number of things can happen: one, they might not have enough staff to keep up with the additional enhanced due diligence (EDD) requirements, such as site visits. In this case, we assisted a large regional bank with conducting their high-risk customer site visits. We were able to create a schedule that fit the requirements of that institution’s policy and budget. Second, if they’re inadequately staffed, it can cause them to get so far behind in backlog of alerts/cases that they have difficult catching up and ultimately could lead to a look-back. We assisted a mid-size regional bank with reviewing alerts/cases during peak periods specific to their business, which happened twice a year. In another situation, we provided case analyst support to a small community bank that requested additional staff to assist them through a look-back by completing the case investigation and annotating before closing or escalating the case. Through this service, we provided them the experience they needed quickly and under-budget.
And finally, there are times when an institution needs to conduct on-going compliance monitoring – this is to be sure that the team members are following the procedures the BSA department put in place. To that end, we have also helped a mid-sized community bank a few times in a quarter by conducting QA on the work of their team. This freed them up from doing so, allowed it to be independent from them bank, and most importantly, allowed us to identify gaps in their training or program.
