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Case Study

Mitigating Financial Crimes Risk by Defining and Executing New SARs Examinations Processes

Results at a Glance

  • 7,500 triage alerts reviewed
  • 15,000 investigation cases completed within 18 months
  • 94% retention of placed staff throughout our engagement
  • Tens of millions of dollars in potential fines avoided by meeting compliance/regulatory operational needs
  • Reduced overhead costs by 20% by setting up a near-shore solution to complete work and optimize the client’s budget

 

Key Success Factors

  • Sourced, screened, hired and trained 56 highly specialized triage and case investigators, data entry analysts, and SAR filing professionals within Canada and the U.S.
  • Completed the alert triage process in Canada two weeks ahead of schedule and received two extensions for investigations team in the U.S.
  • Provided project management expertise to create much-needed process documentation of all processes, including training of all resources
  • Expanded scope of work to take a solutions-oriented approach to addressing the client’s needs

Business Challenges

Avoiding Severe Fines and Protecting Their Customers

Our client is a fast-growing digital payments service company that specializes in providing international money transfer and remittance services to more than 130 countries around the world. Under the Bank Secrecy Act of 1970 (BSA), U.S. financial institutions are required to file a suspicious activity report (SAR) no later than 30 calendar days after detecting a potentially suspicious transaction. As part of their responsibility under BSA, the company was obligated to review alerts of potentially suspicious transactions and, if necessary, file a SAR.

As a young company with limited operational infrastructure in place, our client had accumulated a daunting backlog of thousands of alerts. To review all the alerts and file the appropriate SARs within the required timeframe, our client needed additional staff and help establishing a streamlined review process in the future. Failure to review backlogged alerts and expeditiously file SARs could potentially lead to tens of millions of dollars in BSA fines — a devastating setback to a growing financial organization.

They turned to Aston Carter for support in finding more than 40 specialized professionals who had experience conducting triage and investigative activities to help handle the alert backlog.

Our Solution

Uncovering Critical Needs

After hearing our client’s initial ask, we performed additional discovery work and came to them with a customized, scalable solution to help meet their critical business objectives. In addition to deploying a team of triage analysts, quality assurance leads and a team lead to work through their initial backlog request, Aston Carter also set up critical processes to prepare them for future SARs regulatory examinations. This consultative partnership allowed us to collaborate with our client to address previously unrecognized business and process gaps and deliver a robust managed solution that would have far-reaching, positive impacts on their business.

Aston Carter’s lead program manager came to the job with 15 years of relevant experience that she immediately put to use, setting up much-needed processes to systematically triage alerts, review investigations and file SARs accordingly. She managed the sourcing, hiring and training of 44 employees, creating teams of specialized analysts, data entry professionals, investigators and SAR filers to address the needs of the expanded scope of work. She also developed critical workflows, documentation, training and tracking for all the new roles, as the client previously lacked a framework to manage a team of the size needed to complete the work.

We also addressed our client’s most immediate need — working through their backlog of suspicious transaction alerts while keeping budget top of mind. We set up a near-shore solution to have the triage process performed in Canada, while being managed by Aston Carter in the U.S. — a change that reduced their overhead costs by 20%. The team was able to quickly work through the client’s initial backlog of 6,500 triage alerts. Given our efficiency, the client asked us to review an additional 1,000 triage alerts — bringing the total triage alerts reviewed to 7,500 — allowing them to focus on other key business priorities.

Additionally, the U.S. Investigations Team was originally forecasted to complete 1,625 investigation cases. However, because of the quality and performance of the team’s work, the U.S. Investigations Team received two extensions and has since conducted approximately 15,000 investigation cases.

Throughout the course of the project, our lead program manager maintained a high-touch relationship with our client, providing daily check-ins and weekly metric reports, including updates on productivity, SARs filing aging and quality assurance scores. By regularly consulting with the client on process recommendations to streamline and optimize work, the project was kept on track.

Results

Value Beyond Staffing

Throughout the course of our partnership with our client, our U.S. Investigations Team and Canadian Triage Team collectively reviewed 7,500 triage alerts and conducted over 15,000 investigation case reviews.

Our ability to anticipate our client’s current and future needs led to expanding our initial three-month engagement into an 18-month consultative partnership, with the potential for future collaborations. This shift from a staffing focus to a managed solutions offering empowered our client with a near-shore operation, managerial oversight and teams of specialists to successfully meet their critical business and regulatory objectives. The savings in avoided fines, along with the sustainable process improvements and teams we established, created long-term value for our client.

Our retention rate for the staff placed during the project was over 94%. This allowed us to maintain institutional knowledge and a consistency of work within the team. Our client was highly satisfied with the team’s performance and anticipates keeping many of the staff on in a full-time capacity. 

By offering a more robust workforce solution beyond their original staffing request, our client was able to feel confident they found a trusted partner invested in their success. They also avoided incurring financial penalties reaching into the tens of millions that could have otherwise threatened their business.

“Aston Carter has been a true partner with our organization for more than a year. They have provided strong temporary resources who are dedicated to a job well done, including the program leader. She has led the team of resources with excellence on every level. She selected the best candidates, created and provided exceptional training, ensured productivity and quality were well above expectations and maintained the highest levels of professionalism throughout. In short, Aston Carter and the program leader made my life as BSA Officer easier.”

AMERICAS BANK SECRECY ACT OFFICER, DIGITAL PAYMENTS SERVICE COMPANY