Case Study

Transforming AML function clears the way to 40% greater productivity

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Who we worked with

A Fortune 500 bank holding company specializing in credit cards, home loans, auto loans, banking, and savings products.

What the company needed

To transform its anti-money laundering (AML) operations in order to improve compliance with existing and new AML regulatory reforms.

How we helped

Brought in talent, technology, and process expertise through our AML center of excellence (CoE) that eliminated the client’s program deficiencies while transforming and standardizing its AML processes.

What the company got

Full AML regulatory compliance, zero backlog in only six months, drop in aging alerts from 90 to less than 50 days, and a 40% increase in productivity.


It’s the notification every financial institution dreads… AML operations deficiencies identified by the Office of the Comptroller of the Currency (OCC)

When our client received its notice from the OCC, it knew it needed to quickly and expertly address multiple issues throughout its overall AML program, including:

  • A compliance backlog of 400,000 transactions alerts
  • A large volume of alerts aged over 90 days
  • A soaring volume of transactions
  • Excessive manual intervention, which led to errors, low productivity, and high cost per surveillance

To prevent future compliance issues, the company also needed to simplify, streamline, and centralize its remediation process for alert processing and transaction monitoring.

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Talent, technology, and process expertise in our AML CoE powered the multi-dimensional solution we created — and continue to run — for our client.

Transaction monitoring remediation
Our Six Sigma and black belt-certified quality team conducted an assessment across the client’s different lines of business to identify gaps in its end-to-end AML process. Then we implemented a centralized and scalable alert-remediation process for effective transaction monitoring across the board.

We used our Smart Enterprise Processes (SEPTM) framework to design streamlined processes and create detailed standard operating procedures that aligned with the client’s procedural guidelines for resolution and escalation of actual or partial false matches. 

We automated and standardized the remediation process across the client’s business lines. This allows us to easily determine volume variances and mitigate surges.

Finally, we created a complete audit trail for the end-to-end remediation process, and implemented a process benchmarking system to identify and eliminate bottlenecks.

Quality control
To make sure all regulatory reporting records were easy to find and access, we created a single repository that includes a list of blocked assets, rejected transactions, and applications/grants of licenses.

To allow the client’s team to identify potential failure modes, understand their effect on the process, and immediately act to de-risk the transaction process, we deployed failure modes and effects analysis (FMEA) for risk assessment at the process and project level.

We also developed operational and strategic controls for the business.

To make sure the client’s team was fully prepared, we developed and delivered detailed, customized training on the new AML alert processing and transaction monitoring processes, their specific areas of responsibility, and how to understand the basis of suspicion, identify red flags, and conduct a thorough analysis. We conduct quarterly training refresher courses to help the client’s team members improve their knowledge and skills, and learn about new developments.

And we established a multi-tiered, tollgate-based training and assessment program for the investigators, lines of business, and work streams.


With our solution, the client quickly became fully compliant with all AML regulations, and we’re now supporting business-as-usual (BAU) alerts. Specific wins we achieved for the financial firm include:

  • Clearing the backlog of 400,000 transaction alerts within just six months
  • Reducing alert ageing from 90 days to less than 50
  • Improving productivity in end-to-end AML investigation work by 40%

Because of the success of the program, the company selected us as its strategic partner for AML alert investigation and enhanced due diligence in the transaction monitoring space.

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