AML and compliance case

A Brattle team worked with the DOJ and FinCEN on the first-ever federal case brought against a chief compliance officer (CCO) for failure to flag suspicious activity and willfully failing to maintain an effective AML program. Our team leveraged our data analysis capabilities, analyzing structured and unstructured data on all transaction activity during the CCO’s tenure to identify potentially-fraudulent transactions for which the company did, and did not, file currency transaction reports (CTRs) or suspicious activity reports (SARs). This analysis became part of the basis for a settlement in the case.