Client: European Multilateral Development Bank
Dates Completed: 05/2022-07/2022
The project was a special initiative reviewing Customer Due Diligence (“CDD”) in light of the publication of the FINCEN files.
NLC was employed by the Bank to investigate the potential impacts of the so called ‘FinCEN Files’ on the Bank. The focus of the work was on:
- Identifying the Bank’s exposure to the entities, individuals and banks identified in the reporting on the FinCEN Files.
- Determining whether the Bank’s current Anti-Money Laundering (‘AML’) and Counter Funding of Terrorists (‘CFT’) policies and procedures (including, but not limited to, those relating to Suspicious Activity Reports (‘SARs’)) could be enhanced to address some of the issues/failings identified in the FinCEN Files reporting.
- Developing a methodology to assess similar “leaks” related to AML/CFT breaches in future.
