Our foremost concern is the safety and soundness of the financial institution.
West Coast AML Services implements explicit and effective Marijuana-Related Businesses (MRB)/Anti-Money Laundering (AML) components in financial institutions' risk management programs. Our firm does this in accordance with former Department of Justice Deputy Attorney General James Cole's memorandums, the Financial Crimes Enforcement Network (FinCEN) Bank Secrecy Act (BSA) expectations along with other federal and state regulations.
West Coast AML Services does not perform work for MRBs. On behalf of the financial sector, our firm conducts careful on-site examinations of MRBs to ensure critical criteria for effective AML compliance are in-place and properly administered. We deep dive to uncover risky vulnerabilities, spot weaknesses that may require immediate corrective actions, and recommend enhancements to existing programs.
Community banks and credit unions often lack sufficient resources necessary to properly manage a large scale, high-risk customer base. West Coast AML Services crafts proactive and preventive strategies and temporarily manages high-risk compliance programs. Our firm provides workforce augmentation to conduct enhanced due diligence, quality control, Customer Identification Program (CIP), reduce backlog and prepare Suspicious Activity Reports (SARs) until the financial institution can effectively manage its compliance program.
For the last several years, many of our team members conducted complex grand jury investigations of financial institutions under the U.S Treasury Department's Capital Purchase Program, commonly referred to as the "Bank Bailout." Through extensive interactions with boards, bank officers and regulators we have strengthened our banking industry expertise and gained insight as to the many potential reputational risks financial institutions face today.
West Coast AML Services examines existing MRB compliance programs with first-hand 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. Prosecution Mitigation Reviews keep our clients from running afoul of the Department of Justice, FinCEN and law enforcement.
Attorney General Jeff Sessions has criticized FBI Director James Comey and Attorneys General Eric Holder and Loretta Lynch for not vigorously enforcing the prohibition on marijuana. Going forward, we expect DOJ to closely scrutinize regulatory environments in pro-marijuana states and set new law enforcement targeting policies. It is imperative for any financial institution banking marijuana to carefully craft enhanced due diligence programs for this unique high-risk customer base. West Coast AML Services was designed solely to protect the safety and soundness of financial institutions that bank MRBs.
Terry M. Neeley
Managing Director and Founder
Our team brings a wealth of knowledge and expertise to the table with varying backgrounds in Federal law enforcement, banking, compliance and certifications, including Anti-Money Laundering Specialist (CAMS), Fraud Examiner (CFE), Public Accountant (CPA), and Forensic Interviewer (CFI). Many held Top Secret security clearances when they were federal government employees.
If you have questions or would like additional information, please call 415.948.1903 or complete the form below. Thank you
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