BSA/AML Program Development

Desired Capabilities

Regulatory Compliance
Governance and Policy
Comprehensive BSA/AML Program Development
Defined Operating Model - Roles and Responsibilities
Training and Implementation Plan Creation

The Situation

An indirect lender was launching a direct lending program with a partner bank, which required a comprehensive BSA/AML compliance program to be developed. With a very tight timeline to develop, test, train and implement the program, the client reached out to Spinnaker to assist.

The Challenge

Deliver a comprehensive BSA/AML Program tailored specifically to direct lending. The program must comply not only with all applicable regulatory requirements but also meet the mandates set forth by the partner bank. The program and supporting documentation needed to be created, tested, associates trained, and implemented within a one-month timeframe to meet the target date.

Meaningful Outcomes

Created a custom BSA/AML Compliance Program specific to the client needs - partner bank direct lending relationship.
Team collaboration throughout the institution. This project had a tight deadline and stretched resources. It was critical for Spinnaker to take the reins and drive this engagement to remove the burden of development. This allowed the client Compliance team to focus on other high priorities for the implementation of this product. Spinnaker provided knowledgeable resources and quickly integrated with the core team to deliver a tailored product, on time.
Created a comprehensive resource with interactive reporting and identified roles and responsibilities.

"We had a great experience with [consultant]! She was so easy to get along with, responsive to timing and the ton of work we threw at her in such a short amount of time. Wonderful experience!"

Our Approach

Phase 1: Initiation and discovery. Identify the initial core team and areas with daily monitoring and reporting responsibilities. Identify existing resources including staffing, established policies and procedures, technology and third-party services. Interview core team and identify roles and areas of responsibility.

Phase 2: Perform a risk assessment to identify and prioritize areas of greatest risk. Through the risk assessment, develop a program status and list of current needs.

Phase 3: Develop a written program with the required BSA/AML elements tailored to the risk appetite, as defined in the risk assessment, and size of the institution.

Phase 4: Develop an implementation plan. Identify teams responsible for training, implementation target dates and periodic updates and reviews.