Trust & Investment Bank Cease & Desist

US Private Bank

This prestigious National Private Bank did not meet regulatory requirements during the Safety and Soundness examination, and was ordered to discontinue adding new client accounts due to BSA/AML compliance violations.
The Bank's internal staff estimated it would take 24 months to resolve the regulatory issues.
The Board wanted to resume the bank’s revenue growth, to reestablish assurances of strong regulatory compliance and controls, and “to clean-up” all sub-standard client documentation and reporting requirements.
The LoBue Group was hired to examine all records, fix the problem and to develop an ongoing process preventing the situation from re-occurring in the future.

Examined all client relationships and information retained by the bank (approximately 70,000 private banking relationships).
Develop and execute a plan to acquire missing/unclear client information. The plan included the hiring of 100 temporary staff.
Make recommendations to discontinue questionable client relationships.
Developed and implemented a new process for client acquisitions and on-boarding.
Provide key management indicators to continually monitor and control the quality of client data (involving periodic client audits, and statistical checks to provide an early warning system).

LoBue had undertaken the project and organized a team of LoBue consultant and bank personnel for execution.
The program was rolled out within five weeks from the start and concluded after five month of execution resulting in completed client information and some discontinued relationships.
The outside regulatory agency was invited to perform an audit 5 months ahead the next planned yearly “get in compliance audit”.
The bank passed the external audit and was given permission to resume its new client acquisition and substantial revenue growth.
A projected resolution of 24 months was accomplished in 5 months and regulatory issues were resolved before 1 year.