West Coast AML Services does not provide services to the cannabis industry. Our expertise is in managing complex risks under the Bank Secrecy Act and federal money laundering statutes to minimize the risk of federal prosecution and regulatory enforcement actions. We help keep our clients from running afoul of the Department of Justice, FinCEN and regulators.
Most financial institutions that do not bank marijuana-related businesses nevertheless have "ancillary accounts." We have found that ancillary accounts are ripe for money laundering and pose a great risk to the integrity of every compliance program. Our firm crafts risk management programs specific to ancillary accounts, consistent with the institution's risk profile. We help keep our clients from running afoul of the Department of Justice, Criminal Division's Narcotic and Dangerous Drugs Section, Money Laundering and Asset Recovery Section, Organized Crime Drug Enforcement Task Forces Program and HIDTA.
West Coast AML Services real-world training curriculum focuses on the unique challenges of banking marijuana-related businesses. Our extensive and recent experience in conducting federal money laundering investigations allows us to deliver training programs tailored to current federal law enforcement operations and policy.
West Coast AML Services provides anti-money laundering subject matter expertise to mitigate and manage compliance risks associated with MRB banking. We prepare risk assessments focused on U.S. Department of Justice enforcement priorities and create the structure, policies, procedures and controls of risk management programs within the context of BSA/AML compliance specific to marijuana-related businesses.
West Coast AML Services examines compliance programs with firsthand insight into the prosecution of financial institutions and bankers by the Department of Justice under federal money laundering statutes (18 U.S.C. §§ 1956 and 1957). We recommend program enhancements, immediate corrective actions, tailor training for BSA officers and senior management, and advise the Board on oversight.
It is expected that the Department of Justice will continue to assess the quality and effectiveness of state and local regulatory and law enforcement environments when creating targeting priorities. Keep in mind, FinCEN's guidance clarifying BSA/AML expectations for financial institutions providing services to state-regulated MRBs does not alter any provision of the BSA, including the criminal penalties provided for in 31 U.S.C. Section 5322 and 31 C.F.R. Section 1010.840.
West Coast AML Services was created to manage the unique challenges of banking state-licensed MRBs and minimize the possibility of prosecution under federal money laundering statutes (18 U.S.C. §§ 1956 and 1957) and regulatory enforcement actions. We are committed to protecting the safety, soundness and reputational integrity of financial institutions that are developing compliance programs consistent with federal guidelines and enforcement priorities. Our work has withstood federal and state regulatory examinations.
Terry M. Neeley
Founder / Managing Director
“If they have rigorous compliancy all I can really say is they are less likely to get our attention, but I can’t go out and tell banks if you have rigorous compliance, you have immunity." - The U.S. Attorney for the District of Colorado, October 2018