Engagement with the Corporate Compliance Monitor overseeing a global bank’s Deferred Prosecution Agreement

Client Summary

In 2012 as part of a Deferred Prosecution Agreement (DPA) with the US Department of Justice (DoJ), a global bank (‘the Bank’) was fined nearly $2 billion due to AML & Sanctions violations. In accepting the terms of the DPA, the Bank agreed to be subjected to the evaluation of a Corporate Compliance Monitor (the Monitor) to assess the Bank’s continued compliance with the terms of the DPA.

Project Objectives

  • Since August 2013, Bovill have supported the Monitor who is responsible for overseeing the Bank’s adherence to the terms of the DPA. This is primarily executed through a combination of in-country reviews and thematic reviews
  • Our role is to provide expert resource and workstream leadership on topics including KYC, transaction monitoring, SARs, information sharing and exit management, sanctions, proactive compliance, governance, and policies and procedures

How Bovill Helped

  • Bovill have been retained for over 4 years as the only independent UK regulatory consultancy providing AML & Sanctions expertise
  • The global footprint of an institution the size of the Bank lends itself to a global assessment. We have been at the forefront of reviews across 5 continents spanning 23 countries to date, involving over 25 Bovill consultants
  • Bovill provide subject matter expertise across a number of areas including KYC, Transaction Monitoring, SARs, Governance & MI, Sanctions, Trade Finance, and Correspondent Banking
  • As part of this engagement we have assessed financial crime compliance governance arrangements such as Senior Management oversight, financial crime compliance escalation channels, internal and external reporting structures, MI content, remuneration and disciplinary structures, and proactive compliance controls both at the local and global level
  • We work with the Monitor performing end to end reviews of chosen subject matters. On a broad level this encompasses planning, procedural understanding, testing and reporting
  • Bovill adds value to the process with its blend of industry (CF11s), regulatory (FCA) and consulting experience
  • A significant number of Bovill consultants have been responsible for workstream reports that ultimately are delivered to the Bank, the FCA and the DoJ

Results

  • Our team is helping the Bank on their regulatory journey
  • Our goal is to help the firm maximize their compliance capabilities by providing a thorough assessment of their financial crime compliance framework
  • The output of our reports drive regulatory change within the Bank with the goal of having a robust financial crime compliance function
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