Remediation.
From finding to closure. A four-phase path.
Mobilise.
Senior partners and a delivery lead are on site within 72 hours. Engagement letter signed, scope locked, governance set up, regulator and board points of contact agreed. The first week is about stabilising the file, not solving it.
Diagnose.
Findings mapped to root causes — not symptoms. People, process, data, technology, governance all examined. Board and audit committee briefed with the unvarnished picture. The plan to close the order is built here.
Execute.
Policies rewritten, controls rebuilt, processes redesigned, technology reconfigured, and training delivered. Second line validates as we go. Evidence is captured continuously — never reconstructed at the end.
Close-out.
Sustainability proven through repeated cycles of monitoring, testing, and reporting. Regulator-facing close-out submissions prepared and defended. We stay engaged until the file is closed.
Eight findings we see every quarter.
BSA / AML Program Deficiencies.
Inadequate risk assessment, weak transaction monitoring tuning, untimely SAR filings, and gaps in the four pillars.
Sanctions Screening Failures.
Look-back programs, screening rule deficiencies, OFAC false-positive overload, and PEP / adverse-media gaps.
BaaS & Third-Party Risk.
Sponsor bank oversight failures, fintech program risk, vendor due diligence gaps, and OCC / FDIC third-party guidance.
Consumer Compliance Issues.
UDAAP, fair lending, Reg E, Reg Z, ECOA, CRA, and fee-related consumer harm findings.
Governance & Oversight.
Board oversight, three-lines-of-defence gaps, committee structures, and management information weaknesses.
Internal Audit & Testing.
Audit coverage, frequency, depth, independence concerns, and testing program design.
Crypto & Digital Assets.
NYDFS BitLicense, VASP frameworks, FINMA Travel Rule, and exchange operational compliance.
Data, Technology, & Models.
Data quality, model risk management (SR 11-7), system controls, and reporting reliability findings.
Regulators we run remediations with.
Federal Bank Regulators.
OCC, FDIC, Federal Reserve, FinCEN, CFPB — Matters Requiring Attention (MRA), Matters Requiring Immediate Attention (MRIA), Cease & Desist orders, and Consent Orders.
State Regulators.
NY DFS, California DFPI, Texas DOB, and other state banking departments — consent orders, supervisory letters, and money transmitter findings.
Credit Union Regulators.
NCUA and state CU regulators — CAMELS downgrade remediation, DORs, Letters of Understanding & Agreement, and conservatorship support.
FINMA & Swiss Authorities.
FINMA enforcement, SRO findings, AMLA / FinIA proceedings, MROS escalations, and Swiss banking law compliance restorations.
GCC Regulators.
VARA (Dubai), DFSA (DIFC), FSRA (ADGM), Saudi SAMA — VASP findings, AML enforcement, and licensing remediation.
European Regulators.
FCA, ECB SSM, national competent authorities — Section 166 reviews, supervisory findings, MiCA readiness, and AMLAR program restorations.
What close-out looks like at the regulator's table.
BSA / AML Consent Order · OFAC Look-back · Governance Restoration
We've been there. We know what closes the file.
A 30-minute call with a partner. We'll walk through the finding letter, the board exposure, and what the remediation path realistically looks like for your firm.