Conducting a 130-Country AML Risk Assessment for a Federal Government Agency +
Chartwell undertook a 130-country Anti-Money Laundering risk assessment for a federal government agency preparing to launch an international financial product. The scope of the engagement included the creation of a full assessment matrix; provision of narrative explanations of rankings and full reproducible methodology; procedures for the client to perform future iterations as necessary for additional countries; and executive summarization for the client’s internal stakeholders. Chartwell identified the relevant subject matter and utilized a small team of professionals with over 90 years’ combined AML, money transmission, financial services and project management experience.
Providing BSA/AML Expertise and Compliance Program Drafting Assistance +
An international payments processor sought a consultant to assist with BSA/AML compliance requirements that included: establishing policies and procedures; selecting a monitoring system; conducting training; interviewing compliance staff candidates; providing an annual independent review; and conducting non-legal opinions on the applicability of state money transmitter licensure and money services businesses registration with FinCEN. The services were needed in conjunction with the launch of a new person-to-person money transfer product platform that will be sold to financial institutions. To start the project, Chartwell was assigned to design a BSA/AML compliance program with detailed policies and procedures, after gaining an understanding of the company’s business model. Chartwell then provided written BSA/AML training course material. We assigned a consultant with nearly 30 years of experience in financial services compliance and exceptional background in payments and money services businesses.
Supporting Payments Company through Creation of AML Compliance Vision +
Chartwell provided guidance to a Silicon-Valley backed emerging payment service company to ensure their compliance with anti-money laundering regulatory requirements. The service provided assisted in product design and implementation and included a gap analysis from a product and systems perspective, advising on identification and validation of relevant data in the existing systems, and generation of policies and procedures to ensure future compliance. A respected consultant with over 30 years of experience in AML was sent on-site at the client's request and provided key assistance in the company's establishment of an implementation vision.
Compliance and State License Administration Outsourcing
Serving as Outsourced BSA and State MSB Licensing Administrator +
An international money services business sought a consultant to assist with a broad range of BSA/AML compliance and state licensing matters in the U.S. that have included: serving as outsourced BSA/AML compliance and state license administrator; applying for and serving in a project manager role for state money transmitter license applications; establishing compliance policies and procedures; conducting compliance training; conducting non-legal opinions on the applicability of state money transmitter licensure and money services businesses registration with FinCEN; and producing a handbook of state money transmitter requirements. These services have been needed in conjunction with the launch of the company’s business in the U.S. As this client’s needs have evolved, we have assigned a team of consultants with a combined 190 years of experience in financial services compliance and exceptional background in payments and money services businesses.
Assisting a Bank With BSA/AML and Serving as Temporary BSA Administrator +
Chartwell assisted a regional immigrant-focused bank with necessary enhancements to its BSA/AML Program, as their unique customer base required uniquely qualified consulting services. During some of this time, we served as the bank’s BSA Administrator until the customer hired a full-time compliance officer. The customer's satisfaction with our expertise has led to numerous open ended extensions of our contract to further expand the scope, which we are pleased to accommodate. We continue to assist this customer with the establishment of policies and procedures, risk assessments, high risk monitoring and international trade finance monitoring methodologies. Chartwell assigned a consultant with expertise in BSA/AML with 30 years of experience that was locally available, substantially reducing travel costs for needed site visits.
Outsourced Compliance Reviewer
Providing ACH, Consumer Compliance and BSA Independent Reviews +
Chartwell provided independent review services to a bank for their ACH Compliance, Consumer Compliance and BSA/AML Compliance programs. These reviews were tailored to meet the bank's obligations under relevant NACHA, consumer regulations and FinCEN regulations as well as the bank's own policies and procedures. Chartwell has now been engaged to continue a reocurring schedule of independent testings for the next year, to meet the bank's testing needs in a way that fit best with their available resources. Two seasoned Chartwell consultants with over 50 years' combined experience have been made available to perform these regular reviews.
Providing Consumer Compliance Program Reviews +
Chartwell has recently executed a number of bank consumer compliance program reviews, a very important area as the CFPB intensifies its scrutiny of bank loan and deposit activities. We have also been engaged for a compliance review by a regulated financial institution which is preparing for future CFPB examinations. Our bank compliance work, led by consultants with over a quarter century of regulatory experience, has covered the following regulations and programs: Regulation B, C, D, E, F, G, H, M, N, O, P, V, X, Z, AA, BB, CC, DD, GG, FACTA, MDIA, SCRA, Home Ownership Counseling, Mortgage Loan Officer Compensation, Right to Financial Privacy Act, FDIC Deposit Insurance Disclosures, Advertising, Public Notices, and Signage assistance.
Assisting a National Bank with a Consumer Overdraft Protection Program Exam +
A national bank engaged Chartwell's assistance in responding to an examination by the OCC on their Overdraft Protection Program and related compliance responsibilities. Updated policies and procedures were delivered to the bank within seven business days of the start of the project, allowing a timely response to the OCC exam. Amendments to related policies and procedures, including specific branded product-specific overdraft programs, were drafted by a senior consultant with over 25 years of experience in banking and regulatory compliance.
Facilitating Compliant International Correspondent Banking +
Chartwell recently assigned five individuals to be separately interviewed by a client organization for their views on the regulatory compliance requirements affecting U.S.-Mexico correspondent banking relationships. Our interviewees includes Dennis Lormel (former FBI Financial Crimes Section Chief); Allan Schott (former OCC Chief Counsel); Bob Pasley (former OCC Assistant Director of Enforcement and Compliance); James Wright (former OCC examiner); and Kris Welch (former long-tome bank compliance officer). Each of these individuals has extensive resumes of working with international organizations or overseas.
Enterprise Risk Management
Establishing Enterprise Risk Management Best Practices +
A national bank’s retail payments arm hired Chartwell to establish a formalized control framework that includes an industry standard Risk Control Self Assessment (RCSA) process. This initiative has provided the customer with the infrastructure and tools to migrate to a standardized enterprise process for identifying, assessing, controlling, and reporting all of the risks in their business. We are helping to design control improvement plans for processes with unacceptable residual risk/control deficiencies, as well as assist with the design of simplified and standardized control process flows for complex and disparate practices. Chartwell may also train the bank’s internal resources in facilitation, and serve as the facilitators for the first RCSA cycle. Our consultants have extensive backgrounds in RCSA facilitation, banking operations, credit cards, audit, compliance, technology and credit.
Conducting Interest Rate Risk Assessments +
Chartwell assisted a strategic partner with conducting an assessment of interest rate risk (IRR) metric selection and application for a large national bank, providing our written and verbal opinions on gaps relative to both better practices and regulatory requirements, as well as our insights on data, analytics and measures, governance processes, and reporting to refine the financial institution’s overall IRR measurement capability. We assigned a former senior bank safety and soundness examiner with approximately a quarter century experience in multiple federal regulatory agencies.
Providing Quick, Reliable Regulatory Guidance to a Regional Bank +
In a period of less than two weeks, Chartwell provided multiple written regulatory opinions to a regional bank that subscribed to the HelpDesk service. No new contract or special arrangements were necessary, and within a couple days of each inquiry a team of compliance professionals with more than 50 years’ compliance experience wrote and cross-checked three unrelated concerns affecting this bank, demonstrating the flexibility of the HelpDesk product.
Mergers, Acquisitions and Transfers of Control
Assisting Financial Services Business with a Transfer of Control +
Chartwell assisted a financial services software business with identifying the regulatory requirements associated with acquiring control of a licensed money transmitter. The work included providing guidance on sequencing and structuring the deal in relation to the regulatory process; communicating and sounding off ideas with regulators; providing non-legal guidance during regulatory strategy sessions with company executives and counsel; identifying and assisting with applications for approval and better defining requirements in states which do not have specific rules; providing suggested talking points for use with regulators; and providing suggestions on notifying the surety bond broker, Secretaries of State and banks concerning the material event.
Preparing Key Documents For a National Bank Acquisition +
Chartwell's consultants assisted in the preparation of key documents related to the acquisition of a National Bank by an interested third party. Drafting the necessary documents was performed by Chartwell with discretion and haste to protect the viability of the transfer, and necessary due diligence was performed to ensure the appropriateness of the acquisition. Chartwell's expertise facilitated the regulatory approvals necessary to allow the client to move forward the transaction.
Providing Regulatory Due Diligence Assistance on Investment Candidate +
A venture capital firm sought Chartwell's regulatory expertise in vetting a prospective acquisition. Two consultants with over 35 years' combined audit and M&A experience were assigned to audit the provided third documentation, thoroughly examining their validity through rigorous due diligence over a compressed ten day schedule. Upon detailed review of the third party's organizational documentation and reports, Chartwell was able to recommend a course of action and certain necessary remediations prior to completion of the proposed investment activity.
Providing Compliance Due Diligence for Prominent Venture Capital Firm+
Chartwell was hired by a prominent venture capital firm and completed compliance due diligence of the prospective investee in less than two weeks from contract signing. The investee, an emerging payments business, responded favorably to our performance and consequently hired us directly to assist them with compliance matters.
State Money Transmitter Licenses
State Money Transmitter License Applications for Online Remittance Business +
Chartwell took just seven weeks to complete money transmitter license applications covering 50 states and territories for a venture-backed online remittance business. The first application was approved in just two days after submission by the state, testifying to the quality of the product done under rigorous time pressure.
Consulting on State Money Transmitter License Application and Project Management +
Chartwell completed applications for state money transmitter licenses in 47 states and three U.S. jurisdictions on behalf of a publicly traded customer. The project was successfully completed within an incredibly fast six month period and almost exactly within the initially estimated budget. The client had nearly a dozen licenses approved by just after the project’s completion. Part of the reason the organization chose Chartwell is due to the company’s unique software and methodology capabilities to project manage complex initiatives like state license application processes. Our project leaders were also veterans of state licensing and money services businesses, having well-developed relationships with personnel throughout the state regulatory agencies.
2Regulatory Compliance Framework Training for Money Services Businesses+
Chartwell was hired on one day’s advance notice by a publicly traded financial institution software business to provide a full-day crash-course on the regulatory compliance framework for money services businesses. The engagement helped the customer win a major AML software deal, and to subsequently hire Chartwell again.