MBAF’s Regulatory Risk Solutions group focuses on the regulatory matters that provide the most significant challenges and regulatory risk to our clients. 

BSA/AML/OFAC compliance is again at the center of increasing regulatory expectations and scrutiny after taking a back-seat to asset quality, capital/ALLL adequacy, and liquidity risk during the onset and aftermath of the financial crisis. BSA/AML/OFAC examination and enforcement affects institutions of all sizes, particularly in geographies like Miami or New York City where the Financial Crimes Enforcement Network (FinCEN) continues to issue multiple Geographic Targeting Orders (GTOs) applicable to even non-banks. 

Enforcement activity in the form of Matters Requiring Attention (MRAs), private Memorandums of Understanding (MOUs), and Consent Orders are on the rise for even the smallest of financial institutions with less than US $1billion in assets. Institutions of all sizes are expected to have robust customer risk scoring and transaction surveillance models supported by sophisticated (and often costly) automated software platforms. In addition, the regulatory pressure is not limited to traditional banks either. Kevin Goodman, Associate Director for Broker-Dealers from the SEC’s Office of Compliance Inspections and Examinations, has put the broker-dealer industry on notice that they are expected to have robust, comprehensive BSA/AML compliance programs with sophisticated automated risk scoring and transaction surveillance models. 

MBAF provides “risk-appropriate, fee-reasonable solutions.”  Our Regulatory Risk Solutions practice has created a BSA/AML/OFAC operating model to facilitate discussion, program assessment and roadmap (PAR), and audits of an institution’s BSA/AML compliance program.


MBAF derives a wealth of knowledge from deep industry experiences and regulatory interactions. We built a framework of BSA/AML/OFAC compliance best practices to assist our clients stay a step ahead of the BSA-AML regulatory curve.

Key services include:

  • BSA/AML/OFAC compliance program assessment and roadmap (PAR)
  • Internal audit / independent testing
  • Organizational BSA-AML risk assessments
  • Regulatory enforcement remediation
  • Process and control enhancement
  • Transaction surveillance model validations
  • Transaction surveillance model parameter calibration
  • Customer risk scoring model validations
  • System selection and implementation
  • Custom software development
  • Suspicious activity look-backs
  • BSA/AML/OFAC board, management, and staff training