The USA PATRIOT Act’s Section 352 requires financial institutions to establish an Anti-Money Laundering Program (“AML”) that will help prevent and detect money laundering and the financing of terrorism. Increasingly, U.S. financial services regulators have been meting out severe penalties for programs that do not adhere to acceptable standards. These measures can result in a loss of public confidence and shareholder value. Regulators require financial institutions to risk-rank their customers, know their customers, obtain robust identification documentation on them and perform enhanced due diligence on the ones posing the highest risks. In addition, financial institutions are required to monitor transactions to ascertain when a customer's activity deviates from its anticipated or stated activity and investigate such activity to determine whether to file a Suspicious Activity Report ("SAR") pursuant to the Bank Secrecy Act ("BSA"). Daylight’s team has unparalleled expertise providing a full range of anti-money laundering consulting and investigative services including anti-money laundering look-backs, Know Your Customer (KYC) file remediations, AML/BSA program development and implementation, AML risk assessments, independent testing, training, vendor selection, transaction monitoring, compliance gap analyses and validations and customer identification program and enhanced due diligence program assessment and development.

Daylight's Anti-Money Laundering Services include:

• Know Your Customer File Remediation
• Transaction Look-Backs
• AML/BSA Program Development and Implementation
• AML Risk Assessments
• Independent Testing
• Vendor Selection
• Customer Identification Program ("CIP") and Enhanced Due Diligence ("EDD") Programs
• Compliance Gap Analyses and Validations
• Transaction Monitoring Reviews
• OFAC Compliance & Filtering Services
• Investigative Due Diligence
• Training Services