For over 20 years, IMAG has served many of the largest global and US financial institutions in the regulatory compliance, compliance risk management and operational risk areas. IMAG’s services include compliance advice and guidance to boards and senior management teams; regulatory order remediation and high level project management; conducting risk based and control related diagnostic and vulnerability assessments; developing and integrating compliance within business, operations, audit and technology platforms; and remediation of serious regulatory, risk, audit and control deficiencies. IMAG develops analytical based Compliance Program performance metrics which mitigate compliance risks in the business, operational, regulatory and compliance areas.
We frequently lead key client remediation projects, especially in the anti-money laundering, global sanctions and OFAC areas. Our remediation solutions are especially designed to meet the newly articulated heightened regulatory expectations of the US and global regulatory agencies. IMAG also serves as a qualified independent party when reviews and evaluations are manadated under regulatory order or by internal audit.
IMAG is well known for Anti-Money Laundering and Bank Secrecy Act services which include business driven, risk based approaches to AML Risk, AML Program Effectiveness Metrics, Lines of Defense management, customer onboarding, transaction/alert monitoring, investigation and reporting, the development of human capital plans, compliance self-testing programs, model validation and risk based AML training. IMAG is frequently engaged to provide solutions to financial institutions which have encountered significant difficulties with regulatory authorities in the AML and global sanctions areas.
In 2003, IMAG introduced “COOLMaps™”, a patented, visual, multi-dimensional process map which is highly effective in root cause analysis of internal control risk. COOLMaps™ software has been utilized as a risk diagnostic process mapping tool by major financial institutions, corporations and service providers and regulators.
Representative Consulting Engagements: IMAG frequently acts as a senior project manager/advisor and conducts high-level projects and studies at the holding company, board and executive management levels, often for globally based clients which are under time sensitive orders requiring significant regulatory remediation. Some of noted representative AML engagements include:
- Multiple AML and OFAC related engagements, including oversight for the planning, design, implementation and remediation of all phases of the AML and OFAC risk and compliance programs of one of the world’s largest financial institutions with special emphasis on global correspondent banking, global trade services, global private banking, global securities and sales, embassy banking, corporate and commercial banking and consumer and retail banking;
- Reviewing, for a major global banking acquirer, the remediated AML platform of its US acquired bank (subject to significant regulatory sanctions) to ascertain that the remediated AML program met extensive regulatory remediation requirements and to determine the manner in which the remediated AML program could be integrated into the ongoing AML program of the acquiring bank US branch;
- Planning the structure and functions of a new Group AML program for the 300-plus person AML compliance program of one of the largest US banks and the planning and implementation and integration of that Group AML program into the AML programs of business lines and operations areas;
- Planning the remediation of the structure and organization of the banking and securities compliance and AML programs of a major European banking institution’s US branch network and broker-dealer to meet regulatory requirements;
- Remediating, as a regulator-approved consultant, the MOU and Cease and Desist Orders relating to AML and OFAC sanctions of many foreign bank branches and agencies in the US.
Other Representative Engagements
- Reconstituting the governance structure of the Board of Directors of a major US regional banking subsidiary of a large foreign financial services group to conform to a Federal Reserve 4M Management Order as well to a state banking regulatory remedial order;
- Planning the first Enterprise level compliance program for one of the country’s largest financial services Government Sponsored Enterprises (“GSE”) to conform to US government audit and examination requirements (including a review of the GSE’s potential OFAC exposure);
- Conducting an Enterprise wide review of Enterprise Reputation Risk for one of the US’ largest mortgage lenders;
- Leading an internal investigation of a large collateral mortgage security fraud for one of the largest European banks doing business in the US;
- Leading an independent review and investigative report, as a SEC and NYSE approved consultant, regarding a major internal fraud involving a European banking organization which provided the basis of a new FINRA supervisory rule.