Example Past Projects
Blackstone Compliance has a lengthy track record of helping its clients successfully resolve sanctions and AML-related matters, and our low footprint means that we almost always finish ahead of schedule and under budget. We have served both the public, as part of regulator appointed monitorships and investigations, and private institutions including half of the top-10 largest global financial institutions.
Blackstone has helped global financial institutions implement or optimize their sanctions compliance programs and has conducted in-depth investigations into a variety of sanctions-related matters. We are equally experienced in providing services related to both the policies, procedures, and investigative aspects of a sanctions compliance program, as well as the implementation, tuning, and configuration of both sanctions and AML-related systems.
We were engaged by the U.S. branch of a Top-10 global financial institution to remediate its sanctions compliance program in order to address a consent order issued by its regulator. As a result, the Bank addressed the consent order, received a “strong” OFAC rating from the regulator, and can continue developing business within the United States.
Monitorships, Independent Consultants, and Transaction Reviews
Blackstone has led the sanctions testing of three monitorships or independent consultancies on behalf of the DOJ, Federal Reserve Board, New York Department of Financial Services, and foreign enforcement and regulatory agencies such as the United Kingdom's Financial Conduct Authority.
We frequently conduct reviews of top-50 global financial institutions’ sanctions compliance programs, including testing or validating the program’s policies and procedures, internal controls and technology.
Global Sanctions Implementation
We helped a top-20 global financial institution design and roll out a sanctions compliance program across 30 countries and conduct their global risk assessment. This included not only helping develop their sanctions policy, but harmonizing compliance technology requirements across multiple jurisdictions, and ensuring that each branch was able to adhere to the sanctions policy.
Bespoke Monitoring Systems
Blackstone was engaged by a foreign institution to identify instances of terrorist financing relating to a non-state actor (who is under U.S. sanctions) currently in conflict with the host country. We worked with the institution to develop bespoke transaction monitoring scenarios to identify payments which presented a higher risk of terror financing. Since then, the host country’s regulator has examined the system and asked other banks within the country to deploy similar systems based upon our design.
Compliance Tech Replacement
We developed a complete sanctions IT architecture of a Top-20 U.S. financial institution which consolidated or joined disparate screening and KYC systems, and addressed underlying data quality issues.