AML Manual Creation
Oyster will review relevant written policies and procedures, interview employees, and review relevant records which may include both offsite and onsite review.
We will draft preliminary reports and review those reports with key stakeholders. We will work with these stakeholders to close any open issues and ensure that there is consensus or that areas of difference are documented. We will then present the final written reports to the firm with an overview of the review, matters requiring attention, recommendations, and any other findings. Where appropriate, Oyster will provide the firm with resources to help improve the AML program. The reviews will include AML Program Approval and Oversight, Bank Secrecy Act (“BSA”) Compliance, Customer Identification Program (“CIP”), Financial Crimes Enforcement Network (“FinCEN”) Information Requests/Sharing, Review of Accounts, Including High Risk Accounts, Office of Foreign Assets Control (“OFAC”), Suspicious Activity Reporting, Testing and Training.