AML, BSA, OFAC & Sanctions Compliance Consulting

Anti-money laundering and sanctions compliance is a top enforcement priority for federal banking regulators and FinCEN. Arq Advisory evaluates AML and sanctions frameworks against institutional risk exposure, product and channel profiles, and practical control effectiveness.

Arq’s experience includes evaluating BSA/AML compliance programs, and our team brings direct examination-level expertise to every BSA/AML engagement.

Arq conducts comprehensive BSA/AML compliance program reviews, evaluating the five pillars: internal controls, independent testing, BSA officer designation, training, and customer due diligence. We assess programs against FinCEN regulations, FFIEC BSA/AML Examination Manual procedures, and federal banking agency expectations. Our assessments identify gaps in program design, implementation, and ongoing effectiveness.

We evaluate Customer Identification Program (CIP), Know Your Customer (KYC), and Customer Due Diligence (CDD) processes for adequacy and regulatory alignment. This includes beneficial ownership identification and verification procedures, risk rating methodologies, and enhanced due diligence (EDD) processes for higher-risk customers, products, and geographies.

Arq reviews transaction monitoring systems and processes, including model and threshold oversight, alert generation and disposition quality, and SAR filing timeliness and accuracy. We evaluate whether monitoring parameters are calibrated to institutional risk profiles and whether alert management workflows produce defensible outcomes.

We conduct sample-level SAR testing — evaluating filing decisions, narrative quality, timeliness, and supporting documentation against FinCEN requirements and FFIEC expectations. Our testing methodology mirrors examination procedures used by federal banking agencies.

Arq reviews sanctions screening programs, including OFAC list screening processes, interdiction system calibration, and false positive management. We assess whether sanctions controls are proportionate to product complexity, customer base, and geographic risk.

Arq supports AML program needs in gaming environments, where customer identity verification, cash activity monitoring, and third-party risk create unique BSA/AML exposure requiring specialized compliance frameworks.

Arq Advisory works with banks, credit unions, mortgage lenders, fintech companies, money services businesses, and gaming operators on BSA/AML and sanctions compliance.