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A European bank approached FRA to perform an initial evaluation of its exposure related to customers allegedly involved in money laundering activities. This was of concern to the client given the potential regulatory, financial and reputational implications for the bank. FRA was requested to then perform a deeper dive into other potential connections within the customer base and associated transaction activity.
FRA had a short time span to search the bank’s network for relevant information during the initial review. The FRA team worked vigorously with the bank to define data sources spread across multiple systems, obtain relevant historical information, and to process and host the data in a secure air-gapped environment. FRA deployed a combined team of forensic accountants and data analytics specialists to quickly execute targeted analyses and answer primary questions for the bank. The deeper dive involved a wider data gathering and analysis exercise pertaining to customers, transactions and activity spanning a time period in excess of 10 years. FRA handled significant volumes of both structured and unstructured data, and designed sophisticated data analytics techniques to identify potential connections between customers.
FRA’s initial observations provided the bank with preliminary information, enabling the bank to assess its exposure to money laundering risk posed by a specific population of entities. By incorporating FRA’s deep knowledge of money laundering risk factors, FRA conducted a deeper dive designed to generate a more comprehensive picture for the bank of other potential connections within the customer base and associated transaction activity, and to highlight whether potential vulnerabilities remain.