Assessing the Anti-Money Laundering Program
NYDFS expects that Banks conduct an end-to-end test of the Transaction Monitoring and Filtering Program to ensure alignment with the defined risks and the evolving regulatory landscape.
Our Unique Approach to Testing the Anti-Money Laundering Program
In addition to assessing the level of management oversight, EisnerAmper will validate that the bank has the controls in place to ensure the integrity of the data used in the transaction monitoring and filtering programs.
We will test the effectiveness of the program and benchmark the results against industry standards.
We assess the effectiveness by conducting over 100,000 tests, based on 50 different scenarios and then compare the results to industry standards.
We address the additional challenge of unstructured payment information by providing 150,000 SWIFT messages of all types to validate that the coverage is complete.
We identify the reporting conversion ratio which defines the percentage of alerts generated by the system that end up filing a report.