Experienced money launderers can increasingly exploit the often-fragmented nature of international anti-money laundering (AML) supervision, dispersing the proceeds of organized criminal activity across multiple jurisdictions while avoiding detection and obfuscating investigation. Thwarting these well-organized underworld mechanisms requires expertise with a broad range of tools and the ability to work seamlessly across jurisdictions.
Kroll has extensive experience in helping financial institutions, state authorities and professional service providers meet these challenges head on. Our global network of financial investigators, forensic accountants, data analysts, former prosecutors and enforcement officers gives us the expertise and the cross-border reach needed to unravel complex money-laundering operations. We invest heavily in technology and are at the forefront in using data analysis and social media analysis and other tools to track illicit fund flows through shell companies having multiple layers of ownership.
Kroll’s money-laundering investigations are tailored to the specific needs of our clients:
Financial Institutions
Kroll helps both banks and regulated non-bank financial institutions improve the effectiveness of their AML/counter-terrorist financing (CTF) compliance programs. Our proactive risk assessments identify high-risk activity or customer groups using a combination of transaction analysis, expert open-source business intelligence analysis and know-your-customer (KYC) analysis. We also conduct detailed transaction analysis using advanced data analytics combined with expert insight from Kroll’s experienced AML professionals.
Professional Services Providers
As gatekeepers to the global financial system, accounting firms, law firms, real estate brokers and other professional services firms are under increased regulatory pressure to implement AML/CFT processes and controls. Kroll helps professional services design effective controls based on our extensive knowledge of what works in practice. We partner with firms to conduct a risk-based analysis of enhanced due diligence reports to identify high-risk clients while minimizing false positives. Our support includes customized training and education on evolving AML/CFT threats and countermeasures.
State Authorities
An AML/CTF problem at one financial institution can be indicative of a more systemic vulnerability across a jurisdiction’s banking sector. Kroll provides specialized support to central banks, regulators and financial investigation units to tackle broad challenges. We analyze large datasets to identify suspicious and high-risk activity across institutions, facilitate collaboration and data sharing between agencies and jurisdictions and provide advanced training to regulators, FIUs, law enforcement, and prosecutors in the investigation and prosecution of complex financial crimes.
Case Study – AML Risk Analysis at a Cypriot Bank
A Cypriot bank turned to Kroll after local and international regulators informed the bank that it was at a risk of attracting customers involved in the illegal arms trade and other activities associated with money laundering.
Our investigation began with an identification of relevant risk factors and the development of a customized risk review methodology. We then worked with the bank’s IT team to extract all customer, transaction and monitoring alert data, and to conduct sophisticated data analysis and simulations to identify which customers and customer profiles presented the greatest risk.
Our Compliance Risk and Diligence Team refined our analysis with in-depth public record research of high-risk customers and made specific recommendations to the bank’s compliance department to bolster its customer due diligence procedures.
Case Study – Identifying Widescale Suspected Money Laundering Activity
In 2018, the U.S. Treasury Department designated a Latvian bank as a bank of primary money laundering concern, and in the same year, the country was placed in the Financial Action Task Force (FATF) enhanced follow-up process following a mutual evaluation. Kroll was engaged by the Latvian Financial Intelligence Unit (FIU) to assess the source of funds in the bank and to assist with reforms to avoid being placed on the FATF “grey list.” Kroll drew on a wide range of financial investigation methods and open-source intelligence techniques to identify potential money laundering activity to support the work of the FIU.
Case Study – Investigating the Collapse of Three Moldovan Banks
The National Bank of Moldova appointed Kroll to investigate the collapse of three of the country’s banks due to fraudulent loans that were passed through a group of connected companies.
Our initial investigation determined that improper management influence had been used to bypass controls and approve the loans. Also, changes in the holdings of key shareholders of the three banks were shown to be connected to the fraud.
Follow-up engagements included a detailed forensic audit of the dissipation of funds from the banks to identify the beneficiaries of the fraud and individuals who facilitated the laundering of funds. These findings were used to form an asset recovery strategy pursued in court.
Case Study – AML Program Review at the Islamic Bank of Bangladesh
Since 2015, Kroll has been supporting the Islamic Bank of Bangladesh (IBBL), the largest private bank in Bangladesh, with assessment, upgrade, remediation and implementation of their AML program. We assisted the bank in upgrading its AML standards and procedures in line with global best practices. We carried out an in-depth AML review of the bank, its processes and on-the-ground activities to develop a comprehensive gap analysis of the state of AML at the bank in comparison to global standards. This gap analysis was achieved through data assessments, in-depth interviews, process walkthroughs, branch and office visits, and document and information reviews. We used multiple sources of data, analytics and discussion insights to further validate the gaps.
Kroll, subsequently, as a part of Phase II, provided technical advice and supervisory support to IBBL to develop the necessary platform for AML remediation. Kroll provided consultancy support to IBBL on eight parameters: risk-based framework and analytics; transaction monitoring; KYC and due diligence; independent testing; screening; compliance organization; training; and recordkeeping procedures. Currently, Kroll is assisting the bank in implementation of a high-quality AML program across the country.
