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An international private bank was issued a “Cease & Desist” order from the corresponding banking regulatory authority for failing to effectively comply with anti-money laundering regulations. The bank would have to cease operations if it failed to meet the requirements set forth by the regulators, which included the execution of a tightly monitored plan.

The regulators identified, among others, an important area for action: the creation of a comprehensive and customized ongoing training program designed to develop the abilities necessary to enable compliance. Called by the bank, Genesis performed an in-depth analysis of the bank’s personnel, operations and procedures through an extensive interviewing program, an analysis of the relevant policies and procedures manual, and the creation of cross-functional process maps for that portion of the bank’s operations in question.

With the information gathered during the analysis phase, Genesis mapped the skills and competencies needed for employees to effectively comply with anti-money laundering regulations while performing their jobs and functions. An implementation plan was organized and then rolled-out in the form of a bank-wide training program specifically designed to tackle the deficiencies identified by the regulators.

Upon completion of the program, Genesis continued to assist the bank in its compliance efforts. Additional assignments included:

Preparation of the bank’s personnel for upcoming audit
Design and implementation of additional training programs
Coaching of senior management and board members on managerial and planning issues related to compliance
Creation of a policies and procedures “roadmap” for easier information access
Review and assessment of client files

As a result of Genesis' assistance and the bank's assertive steps toward compliance, the regulators have lifted the “Cease & Desist” order.

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