Anti-Money Laundering & Bank Secrecy Act Compliance

Through our staff and global network of associates, we employ renowned experts in every facet of compliance, from research to regulation.

NFC Global, in conjunction with their sister company, Spectrum Gaming Group, has the capability and worldwide reach to conduct audits and investigations regarding Anti-Money Laundering (AML) issues. These niche services address the growing legal and regulatory concerns regarding this critical issue, which remains a high priority for international law enforcement.

The use of independent, third-party companies to conduct this Due Diligence effort is considered a best practice, rather than using an outside auditing firm that sometimes can be “too close” to a situation to accurately assess risk. We are objective and independent and will tell our clients what they need to know, not necessarily what they want to hear. As the world has become a more global marketplace, the risk factors related to money laundering have increased.

In our risk assessments, we review how controls and policies are implemented and identify actual and potential gaps. During the Audit and Review process, we review and assess AML compliance with company policies and procedures, test the current audit program, review currency aggregation procedures, review existing internal policies and procedures—including high-risk countries, OFAC, and Politically Exposed Persons—review internal audits, review how critical information is gathered and stored in order to identify suspicious transactions and make recommendations how to enhance these procedures or validate that current procedures are sufficient.

Our capabilities for Anti-Money Laundering (AML) investigations include:

  • Risk assessments
  • Audits and reviews
  • Compliance consulting
  • Training programs (the design and delivery)
  • Special investigations
  • Due Diligence

Our compliance consulting team can revise existing AML programs as well as revise and create AML policies and procedures and new compliance plans. The training capabilities we offer include evaluating existing training programs and designing new programs which are developed specifically to the client’s operations. We also provide enhanced customer Due Diligence when the need arises that can be conducted on a case-by-case basis. This enhanced Due Diligence can be expanded to include consultants, board of directors, and compliance committee.

Revisiting Compliance Regularly

Clients should reconsider their AML/BSA compliance efforts regularly to ensure they account for new risks. The main goal of money laundering is to turn “dirty money” into “clean money” through a process of placement, layering, and integration. The creative ways in which criminals adapt to and circumvent regulations require revisiting compliance efforts on a regular basis.

NFC’s managing director, Fredric Gushin, while serving as Assistant Director for New Jersey’s Division of Gaming Enforcement, worked on a task force to implement amendments to the Bank Secrecy Act. Mr. Gushin has over thirty years of AML experience. Other experts working on NFC’s AML investigations include intelligence analysts, attorneys, Certified Public Accountants (CPA), Certified Anti-Money Laundering Specialists (CAMS), a former Vice President of Compliance, and former IRS and FinCEN law enforcement professionals with experience in providing these services to banks, governments, and the casino industry.