Financial Crimes Advisory

It depends on where you operate, who your customers and counterparties are, which currencies you move and what your bank partners require. A U.S. business starts with OFAC: the Specially Designated Nationals and Blocked Persons List and OFAC's other sanctions lists. Once customers, payouts or counterparties carry a U.K., E.U. or wider international nexus, screening usually extends to the U.K., E.U. and U.N. lists, and many U.S. bank partners expect multi-regime screening for cross-border flows.

Lists are not the whole answer: under OFAC's 50 percent rule, an entity owned 50 percent or more, directly or indirectly, individually or in the aggregate, by blocked persons is generally treated as blocked even when it is not named on a list. We help you set list coverage, document the rationale and test that screening works as designed. See sanctions screening and OFAC compliance.

Yes, as investigation support. When an agent, distributor, consultant or other intermediary is suspected of making or facilitating improper payments, we help establish the facts: scoping the review, testing payments, invoices and books and records, examining the third party's due diligence file and contract terms, and identifying the control gaps that allowed it.

Where privilege matters, or a voluntary self-disclosure to the DOJ or SEC is under consideration, the investigation typically runs at the direction of your counsel, and we work inside that structure. Afterwards we help rebuild the third-party diligence and approval framework so the same gap does not recur. See FCPA and third-party anti-corruption diligence.

Yes. SAR quality review and filing governance is part of our AML work. We test a sample of alerts, cases, and SAR and no-SAR decisions against your procedures and FinCEN expectations: whether each investigation is documented, whether the rationale supports the decision, whether filings meet regulatory deadlines, whether narratives explain the who, what, when, where and why, and how continuing activity is reviewed.

We work within your SAR confidentiality controls, and the decision to file stays with your BSA officer or SAR committee: we test the process, we do not replace it. Findings come with prioritized recommendations, documented so your examiner and bank partner can follow the work.

A BSA/AML risk assessment looks at money laundering and terrorist financing risk across your products, services, customers and geographies, and examiners generally expect it to be the foundation of your BSA/AML program. A financial crimes risk assessment widens the lens to sanctions, bribery and corruption, and fraud, using one methodology so management and the board see inherent risk, control effectiveness and residual risk for each area side by side.

Many institutions also keep a separate sanctions risk assessment. The broader view shows where controls overlap, where gaps sit between teams, and where one investment serves more than one program. We can build either assessment, or bring an existing BSA/AML risk assessment into an enterprise financial crimes view.

No. Ethixera Advisory is a compliance advisory firm, not a law firm, and does not provide legal advice. We assess, design, test and help run financial crimes compliance programs, and we work alongside your counsel on legal interpretation, privilege, disclosure decisions and any dealings with enforcement authorities that call for legal representation.