AML Investigation for private bank

Members of the CRA team led an AML program assessment for a financial institution in emerging markets.  The work included the investigation of the origins of investment funds coming from South American sources, established a basis to distinguish legitimate account holders, and developed a protocol to raise alerts on accounts based on a system of risk assessment measurements. The team also devised risk-based due diligence screening and controls to support the bank in developing an automated account opening system for potential customers.