How a Major Commercial Bank Achieved Compliance with Legal and Regulatory Requirements

Background & Challenges

A New York branch of a major commercial bank provides banking services to customers in the United States and is required to comply with U.S. federal and New York State Department of Financial Services (NYDFS) laws and regulations including Bank Secrecy Act, Anti-Money Laundering, and Office of Foreign Assets Control (BSA/AML/OFAC) compliance program requirements. A challenging area for the bank was demonstrating compliance with the requirement that AML transaction monitoring and OFAC sanctions screening systems are designed and operating effectively to identify suspicious transactions and sanctioned entities and individuals to meet federal and NYDFS Part 504 requirements.


BDO was engaged by the bank to provide BSA/AML/OFAC model validation services. BDO reviewed, tested, and validated the transaction monitoring and sanctions screening models to include the integrity, accuracy, and quality of the bank’s source data used in the models; accuracy and effectiveness of system processing logic, parameters, and settings; usage and quality of model output; and the adequacy of the bank’s model documentation and governance framework.

Client Impact

BDO validated the bank’s transaction monitoring and sanctions screening systems to ensure compliance with legal and regulatory requirements and industry best practices. BDO also provided recommended improvements to align with the bank’s anti-money laundering risks, BSA/AML/OFAC regulations, and NYDFS Part 504 requirements.