Transaction Lookback – Major Foreign Bank

February 14, 2023

In response to an action taken by the Federal Reserve Bank of New York and the New York State Department of Financial Services, provided investigation, financial analytical and project management resources to one of the first-ever “transaction lookbacks” performed in connection with a bank regulatory action related to the institution’s systemic failures to detect and report suspicious activity.  The project consisted of an exhaustive review of U.S. based transactions spanning multiple years seeking to identify and report previously unreported suspicious activity.  The project enabled the bank to avoid severe penalties and restrictions being imposed on the bank and led to widespread improvements to the bank’s transaction monitoring, investigation and suspicious activity reporting processes.