A credible counter-terrorism financing program connects enterprise risk, day-to-day operations and board accountability. It is not a stack of policies. We help institutions identify where their products, customers, geographies, payment channels, counterparties and delivery models may be exposed to terrorist-financing or sanctions risk, then design controls proportionate to that exposure.
The Bank Secrecy Act and its implementing regulations create recordkeeping, reporting and program obligations for covered financial institutions. The USA PATRIOT Act added important authorities and requirements, including special measures under Section 311, due diligence for certain correspondent and private-banking accounts, law-enforcement information requests under Section 314(a), and voluntary information sharing among eligible registered institutions under Section 314(b), subject to the applicable conditions. Those authorities interact with suspicious-activity reporting, sanctions compliance, customer identification, beneficial-ownership work, funds-transfer records and regulator expectations.
Our CTF reviews begin with the institution as it actually operates. We interview business, operations, investigations, sanctions, data, product, audit and legal teams. We sample transactions and alerts, examine how risk ratings are produced, and trace an escalation from data ingestion through final disposition. That work frequently identifies gaps between policy language and system behavior: incomplete corridor data, inconsistent alert suppression, weak correspondent-bank visibility, poor agent oversight, blockchain analytics that are not connected to customer risk, or charity diligence that measures paperwork rather than diversion risk.
Remediation is sequenced around exposure. Immediate controls may include manual review, targeted lookbacks, high-risk counterparty restrictions, refreshed watchlists, or revised escalation. Longer-term work can include model changes, governance, staffing, training, independent testing, issue validation and regulator reporting. We write plans that identify owners, evidence, dependencies and completion criteria, because a program is defensible only when the institution can demonstrate how a control works and how it knows the control is effective.
What we do
Our work spans program design, independent challenge, transactional review and remediation. The objective is a risk-based system that can be operated, tested and explained.
- Enterprise and product-level terrorist-financing risk assessments covering customers, geographies, products, channels and counterparties.
- Board and senior-management governance, risk appetite, committee charters, management information and escalation thresholds.
- Customer, beneficial-owner, counterparty, donor, grantee, beneficiary and agent due-diligence frameworks.
- Correspondent banking review, nested-relationship visibility, payable-through risk and USA PATRIOT Act Section 311 preparedness.
- Transaction-monitoring coverage assessments, scenario design, segmentation, tuning, validation and alert-investigation procedures.
- Sanctions screening integration, including customer and payment screening, ownership analysis and escalation to legal counsel.
- Section 314(a) response governance and Section 314(b) information-sharing procedures consistent with applicable conditions.
- SAR decision governance, documentation quality, board reporting and protection of sensitive BSA information.
- CTF lookbacks, root-cause analysis, remediation plans, quality assurance, independent testing and sustainable issue closure.
- Training for directors, investigators, relationship managers, operations teams, agents and humanitarian-program personnel.
Who we advise
Banks rely on us for correspondent banking, payment-chain visibility, Section 311 exposure and governance that connects financial-crime compliance with sanctions and national-security concerns. MSBs and remittance providers seek advice on agents, cash activity, high-risk corridors, hawala and other informal value-transfer indicators. Fintechs use our team to align sponsor-bank expectations with rapidly evolving products, embedded finance and cross-border payments. Crypto exchanges and virtual-asset businesses engage us on wallet analytics, source-of-funds, mixers, hosted and unhosted wallets, Travel Rule workflows and escalation of terrorism-related indicators.
Charities and NGOs require a different calibration. A risk-based CTF framework should protect lawful humanitarian activity, not replace mission delivery with indiscriminate de-risking. We help organizations evaluate donors, implementing partners, beneficiaries, procurement, cash use and access constraints, while documenting licenses, exceptions, monitoring and end-use controls. The result is a program that addresses genuine abuse risk and preserves legitimate operations.
Our approach
We use a four-stage method that turns legal standards and risk information into an operating control environment.
Assess
Map the business, data, geographies, counterparties and existing controls; identify the most consequential exposure.
Design
Set governance, risk ratings, diligence, monitoring, screening and escalation requirements that fit the operating model.
Implement
Translate requirements into workflows, data specifications, procedures, training, ownership and documentary evidence.
Validate
Test design and operating effectiveness, correct root causes, document closure and establish ongoing monitoring.
