EMMA ASATOORIAN, CAMS

Institutional Clients Group (ICG) Investigations

• Execute AML investigations based on internal referrals from the business, operations, and other compliance functions.
• Conduct case analysis by performing EDD and completing all elements of the case/transactional phase that are material to the investigation.
• Collect and analyze information from internal and external sources, internal applications concerning focal and related parties, beneficial owners, and counterparties, as necessary.
• Conduct transactional analysis by identifying if the activity is commensurate with the type of client or business; if the activity can be reasonably explained; identify and investigate irregular transactional activity, illicit/criminal activity, other red flags.
• Determine the AML risk, examining materiality of negative media and prior investigative results, draft and file Suspicious Activity Reports (SARs) consistent with FINCEN requirements.
• Initiate inquiries to country compliance officer/relationship managers; initiate 314(b) inquiries (when warranted) and review/apply responses, determining the disposition of the case.

Affluent High Net Worth and Specialized Services (AHS) Investigations

• Conducted extensive reviews of manually generated cases, system generated alerts and alerts escalated by external monitoring teams involving Affluent High Net Worth clients.
• Reviewed the background information associated with the account utilizing internal applications and any legacy customer due diligence systems.
• Conducted mandatory searches using name variations, account information and negative string searches where necessary and completed the case log template with pertinent screenshots of searches performed.
• Recommended AHS closeout referrals and sent to NAM Financial Intelligence Unit (FIU) AHS closeout designee for coordination with the Business and followed the closeout process for AHS accounts.

Name Screening Searches/ ICG SPF Enhanced Due Diligence

• Performed Name Screening of potential matches escalated or identified during the client on-boarding process, potential matches identified during the Ad Hoc Name Search process which includes Global, US-only, and OFAC updates.
• Conducted Risk Based and Enhanced Due Diligence on ICG Senior Public Figures, utilizing internal applications and external sources, such as Factiva, SAR database, CitiKYC, LexisNexis, etc.
• Provided overall SPF Risk Summary with details of any significant AML risks identified, and discussions of any high-risk indicators.

• Conducted in-depth domestic and international due diligence and background investigations: financial and operations history; legal matters; professional reputation; undisclosed liabilities.
• Collected, analyzed and identified positive/negative information with respect to the subject.
• Prepared comprehensive investigative reports, or portions thereof, from rough draft to finished product.
• Conducted adverse media searches through Factiva; identified the associations of subjects with sanctioned countries; prepared reports with related articles.
• Documented all work performed and maintained files containing work paper and supporting documentation.
• Assisted Senior Director of AML division with management of AML projects: screening, interviewing, on boarding AML workers for major banks; serving as a liaison between the clients and the resources to handle various issues, managing all applicable documentation.
• Reviewed written AML policies, procedures and processes of foreign banks that intended to establish correspondent accounts at a US bank; assessed their overall adequacy of the BSA/AML compliance program; provided recommendations on how to enhance and maintain adequate controls to protect the US bank from money laundering and terrorist financing.