Advisory for boards and executives
Clear answers on financial crime risk for the people who are accountable for it: what the exposure is, what regulators will expect, and what to do next.
Board and executive briefings
Sized to the agenda, from a single board item to a half-day workshop, in English or Spanish.
- Financial crime, sanctions and anti-corruption exposure in plain language
- Enforcement trends and what peers were penalized for
- Directors' oversight duties and the questions to ask management
- Emerging issues, including the terrorist designation of cartels
Independent review and testing
An outside view that holds up when regulators, auditors or correspondent banks ask.
- Independent testing of anti-money laundering and sanctions programs
- Enterprise-wide financial crime risk assessments
- Governance, policy and operating model reviews
- Monitoring, screening and model effectiveness reviews
- Anti-money laundering and sanctions programs of crypto exchanges and digital asset firms
Enforcement, remediation and monitorships
Experience on both sides of regulatory scrutiny, beginning as an examiner.
- Regulatory investigations and look-backs
- Remediation program design and delivery
- Independent monitorships and consultancies
- Correspondent banking reviews and de-risking response
Across the full program
Policies and procedures
Program design, gap analyses and benchmarking against legal and regulatory requirements and industry practice; interpretation of global and local standards.
Independent testing and validation
Risk-based testing of the design and operating effectiveness of anti-money laundering and sanctions controls, including annual independent tests.
Risk assessments
Enterprise-wide and product, business-line and customer risk assessments, methodologies and tools tailored to the institution’s profile.
Know your customer and enhanced due diligence
Analysis, testing and enhancement of KYC and EDD by customer, product, transaction and geographic risk; beneficial ownership and politically exposed persons.
Transaction monitoring and suspicious activity reporting
Case management, investigation and escalation protocols; deployment, validation and calibration of monitoring, screening and due diligence systems.
Look-backs and transaction reviews
Complex anti-money laundering and sanctions look-backs, including those mandated by regulators.
Investigations and due diligence
Complex anti-money laundering, sanctions and corruption investigations; acquisition due diligence on systems and controls; high-risk customer reviews.
Technology selection and remediation
Vendor selection, implementation and calibration of monitoring and screening technology; remediation programs and their validation.
Anti-bribery and corruption
FCPA and UK Bribery Act compliance programs, strategy and investigations.
Training and awareness
Review of existing material and customized training for boards, executives, business lines and operations.
- Ran the monitor liaison office for a global cryptocurrency exchange operating under concurrent U.S. Department of Justice and FinCEN monitorships following a $4.3 billion settlement
- Interim chief compliance officer for a global financial institution, setting its anti-money laundering and sanctions strategy and leading implementation
- Independent sanctions transaction look-back across more than 20 jurisdictions for an Asian-headquartered financial institution, one of the world’s five largest, demonstrating no sanctions violations
- Engaged by an SEC-appointed independent monitor to review the anti-money laundering and sanctions program of one of the largest U.S. broker-dealers
- Investigation for one of the largest Swiss-headquartered financial institutions into account relationships under the terms of its settlement with the U.S. Department of Justice
- Internal review for a global U.S.-headquartered bank following a Department of Justice inquiry into alleged laundering by institutional clients; all regulatory mandates were lifted and no fine was imposed
- 24-month customer and transaction look-back for the U.S. branch of an Asian-headquartered bank; the regulatory mandate was lifted after the review
- Look-backs mandated by the Federal Reserve, OCC, FDIC and FINRA, each satisfying the regulatory mandate
- Consolidated global customer view and high-risk KYC remediation across hundreds of jurisdictions for a global retail and commercial bank, within local privacy law
- Board-level redesign of the anti-money laundering and sanctions program, including systems, for the Asia-Pacific operations of a global payments company
- Support for the board of a U.K. bank through a Financial Conduct Authority investigation and remediation, and Section 166 skilled person reviews
- Enhanced due diligence and onsite reviews in 15 countries on higher-risk brokers for a leading U.S. commodities broker’s clearing relationships
- Programs that allowed non-U.S. banks to establish and keep U.S. correspondent relationships
- Design and implementation of anti-money laundering and sanctions programs for cryptocurrency companies
- Independent testing and board briefings for banks in Mexico and across Latin America
Who he works with
Banks and their correspondents, crypto exchanges and digital asset firms, fintechs and payment companies, and multinational corporates, in the United States and more than sixty countries.
He has worked with regulators and authorities in the United States, Europe, Asia and Latin America, and has briefed U.S. and foreign government bodies, central banks and finance ministries on emerging financial crime issues.
A short call to scope the question
Most engagements begin with a 30-minute conversation about what the board or leadership team needs to know, by when, and in what format. From there he proposes a briefing, a review or a scoped engagement.
For board briefings, independent reviews and advisory inquiries: sven.stumbauer@forwardglobal.com
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