- Engaged in an ambitious effort to upgrade and migrate its existing transaction monitoring operations to regional hubs that utilize a single set of monitoring principles and a common technology platform.
- Enhanced its understanding of the Bank’s AML risk through its enterprise-wide AML risk assessment process, which included the collection of millions of data elements from global source systems.
- Strengthened its core AML management group by completing certain strategic senior hires of employees with extensive experience in the industry and with U.S. regulatory and law enforcement agencies.
- Developed processes to conduct special and separate reviews of certain high risk customers on a global basis.
- Enhanced its Internal Audit team’s AML expertise, staffing and methodology.
Statement On OCC Consent Order
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