FinScan Advisory Services transforms FinScan’s advanced AML screening solutions into a leading-edge compliance risk management solution. Deep AML subject matter expertise, coupled with FinScan’s industry-leading technology and data quality offerings, deliver a holistic solution of high-quality data and innovative, technology-enhanced compliance risk management. Below is an overview of our Advisory Service offerings.
Culture Assessment and Development
An assessment of your compliance program foundation begins with an evaluation of the “tone from the top.” We assist in the evaluation or development of your Code of Conduct, ethics and compliance training, and gifts and entertainment policy and tracking programs, as well as the establishment of a compliance culture.
We can assess your current compliance program to ensure that you have identified and addressed all the relevant regulatory risks, as well as identified, implemented, and assessed all relevant regulatory risk mitigants.
A compliance risk assessment is an essential element to any successful compliance program, as set forth in all applicable regulatory and industry guidance. We assist you in the assessment of inherent risk by collecting and evaluating data on customers, products and services, and geographies. Then, through the identification and evaluation of risk mitigants, we work with you to determine your level of residual risk. We also help you document the results of the risk assessment, as well as the process used to complete it.
Data and Data Governance
Complete, accurate, and timely compliance data is critical to a successful compliance program. We help you identify the key data elements necessary to measure and monitor compliance risk and the performance of internal controls. We also help to develop a data governance framework or integrate compliance data into your existing data governance framework.
Organization and Staffing Assessment
Having an autonomous compliance organization with an independent reporting line to the Board of Directors is a hallmark of a successful program. We can assist you by evaluating your compliance organization reporting structure and span of control (SpOC). We can also assist in the evaluation of the resource requirements, in both quality and quantity.
Training Program and Content
A well-trained staff is integral to an effective program and is one of the many necessary control elements. We can assist you in the development or evaluation of your training policy, training requirements by job function, and training curriculum. We can further assist in the development and delivery of job-specific training content, along with the development and implementation of certification programs.
Policies and Procedures
Documented policies and procedures are a predicate requirement for an effective compliance program. They are also a necessary component of job-specific training, where training on how to do a task is as important as why the task is being done. We can assist you in the development of robust, documented policies and procedures that are integrated with workflows and identify required control points, performance metrics, and reporting.
The use of compliance models is more and more prevalent today. There is also new and expanding regulatory emphasis on compliance models and their effective development, implementation, and use. We assist you in establishing the definition of a compliance model and performing an inventory of activities that meet this definition. We can also assist in drafting or evaluating model documentation. In instances where we have not assisted in the development or documentation of your models, we can provide model validation services.
Every compliance program must be independently tested. We can assist in assessing your current independent testing program or drafting your independent testing policies and standards, program test steps, templates, and workbooks. We can also provide subject matter expertise to guide or execute your independent testing program.
Qualified Independent Consultant
Organizations from time to time become subjects to enforcement orders. Those orders may call for a “Qualified Independent Consultant”. Our subject matter experts have and can serve in this capacity to guide you through your response and remediation efforts.
Lookbacks and Investigations
Many times enforcement orders call for organizations to perform a lookback. Additionally, government agencies may initiate investigations into activities that violate laws and regulations. Our subject matter experts have and can assist in managing and performing these lookbacks and investigations.