OUR SERVICES

Risk Assessments & Management Reporting

Risk assessments designed for brokerage activity
IPSA’s professional staff can assist broker-dealers in executing detailed and customized risk assessments specific to brokerage activities. Many risk assessments in place today have been modeled based on banking interpretations of money laundering and terrorist financing risk.

Customize your AML program to the specific AML risk of your business
A detailed risk assessment forms the foundation for customizing your AML program to your business. This process can be used to minimize your expenditures for services that may not enhance the effectiveness of your AML program as well as provide the basis for defending your decisions regarding types of surveillance processes. Once established, a risk assessment can easily be maintained as part of an AML scorecard process and only requires significant review if the business model changes materially.

Isolate higher risk customers for more effective application of resources
For certain types of business, risk assessments may be extended to the client level. Client risk scoring, while not in broad use among broker-dealers, is effective in minimizing false positives in the surveillance process by isolating clients that should be subjected to different controls and/or surveillance parameters.

Aggregated in an AML Scorecard to facilitate reporting to senior management
Regular reporting to senior management is an important component of a robust AML program. Reporting can be accomplished efficiently by defining key statistics that indicate AML program health and effectiveness in an AML scorecard. By incorporating continuous testing policies and procedures into the scorecard process, broker-dealers can meet CEO certification requirements as well.

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Independent Exams

Exams scaled to meet the needs of your business model
IPSA offers both full independent exams and modular best practices reviews of your AML program. A complete independent exam is designed to evaluate your policies and procedures for completeness and suitability for your business as well as evidence of reasonable execution.

Targeted to the expectations of your regulatory environment
IPSA’s staff provides AML examinations specifically targeted only to AML and the regulatory environment your firm faces. Expectations of broker-dealers under the Bank Secrecy Act (BSA)/USA PATRIOT Act are different than expectations of banks and bank holding companies. While the regulation is materially the same, the structure of the businesses are different and present different challenges in implementation and execution.

Focused to ensure expectations consistent with peer firms
Firms avoid being held to a standard that may put them at a competitive disadvantage with their peers and/or may not reflect the expectations of regulators. A focused independent AML exam clarifies expectations, reduces time expended by AML and field staff and delivers a product targeted to regulatory expectations. Additionally, all independent exams are modular with the ability to scale up or down based on a firm’s ownership structure or exposure to various risks and business activities.

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Suspicious Activity Reporting & Surveillance Process Enhancement

Maximize the effectiveness of your surveillance efforts
IPSA professionals can evaluate your current approach to surveillance to maximize the effectiveness of your efforts to identify and report suspicious activity in a timely manner. Automated transaction monitoring systems represent one tool in the arsenal of an AML surveillance team. This tool adds value only when it is properly calibrated, controlled and monitored by professionals familiar with your business and AML. The appropriate mix of resource dedicated to automated transaction monitoring, case management, manual surveillance and leverage of controls intended for other purposes can increase the effectiveness of your suspicious activity reporting without requiring significant investments in new systems.

Minimize Surveillance Process expenditures through appropriate mix of resources
In many cases, firms should consider a detailed analysis of the AML risk of their business prior to investing in automated tools. Further, those firms with automated transaction monitoring tools in place will benefit from an evaluation of the rules in place to test for completeness of transactional detail, appropriateness of alerts generated, impact of shifts in rule parameters and timeliness of reporting. Education of both the front line and the AML surveillance team can result in improved effectiveness of the surveillance process as well. Surveillance process performance can be integrated into an AML scorecard to ensure continued attention to this critical component of your AML program.

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