Compliance Program Assessment & Exam Preparation
Patomak Global Partners assesses compliance programs at banks, broker-dealers, swap dealers, security-based swap dealers, futures commission merchants, consumer lenders, mortgage servicers, digital asset trading platforms, fintechs, and other financial firms to identify control weaknesses or gaps. The team provides recommendations to remediate identified issues and conducts follow-ups to ensure successful remediation.
The team works with executives to prepare clients for examinations by U.S. banking regulators, the Consumer Financial Protection Bureau, the Commodity Futures Trading Commission, the Financial Crimes Enforcement Network, the Financial Industry Regulatory Association, the National Futures Association, the Securities and Exchange Commission, and other authorities.
We assist firms in designing and implementing compliance frameworks for regulatory licensing to help ensure the approval process, and consummation goes smoothly. To support these efforts, the team develops policies, procedures, and internal controls for trading, risk management, margin, capital, compliance, cyber security, anti-money laundering, know-your-customer requirements, community reinvestment and consumer compliance, and other functions considered during the licensing process.
BSA/AML & Sanctions Compliance
The team strategically supports the design, implementation, and enhancement of BSA/AML and sanctions policies, procedures, and processes, including assessing vendor solutions.
Governance & Supervision
Patomak reviews governance frameworks and advises clients regarding shareholder relations, management duties and responsibilities, risk control, assessment programs, supporting independent review functions (e.g., audit, credit, model, etc.), and committee structures and charters.
Risk Management & Regulatory Reporting
We assess the design and implementation of risk management, trade surveillance, and reporting (SDR, CAT, TRACE, LTR) systems to ensure they meet regulatory requirements.
Team members also review capital, credit, liquidity frameworks, as well as regulatory capital modeling approaches, to ensure clients exceed regulatory expectations.
Examples of the Patomak Global Partners’ risk management and compliance engagement include:
- Supported a bank’s efforts to develop and document risk management processes responsive to Federal Reserve Board findings and requirements, focusing on banking services provided through its clearing account.
- Conducted a comprehensive review of a global financial institution’s trade surveillance program across jurisdictions and products. Review included assessing and providing expert advice related to the trade venue inventory, supervision, and parameter setting.
- Conducted end-to-end trade reporting reviews for multiple swap dealers focusing on large trader reporting, real-time public reporting, and data recordkeeping to assess compliance with CFTC parts 20, 43, and 45.
- Assisted with compliance reviews, annual compliance and risk assessments, and Form ADV filings for SEC-registered investment advisers of foreign investment managers.
- Reviewed and assessed financial firms’ off-channel communication compliance program, taking into account undertakings in recent SEC enforcement actions.
- Assessed compliance with CFTC regulations covering policies, procedures, and controls for several major swap dealers, focusing on supervision, business conduct, clearing and execution, and large trader reporting.
- Conducted independent reviews for a large financial institution with multiple broker-dealers to support CEO certification regarding SEC Rule 15c3-5 (Market Access) compliance, including financial, regulatory, and other risk management controls and supervisory procedures.
- Served as an implementation partner for many firms to successfully secure CFTC and NFA registration as a swap dealer and assisted with end-to-end implementation of a compliance and risk management program spanning trade surveillance, margin, capital reporting, and client onboarding.
- Supported cryptocurrency firms’ successful applications for New York BitLicense and state-level trust company charters, including advising on policies and procedures and conducting required risk assessments.
- Advised bank executives on the requirements, timeline, and regulatory risks related to the application process to become a member bank of the Federal Reserve System.
- Developed processes at banks to stand up a CIP and KYC programs to comply with FinCEN requirements.
- Developed policies and procedures, trained staff, conducted internal reviews, and managed annual employee certification on FCPA requirements.
- Assessed the adequacy of BSA/AML and sanctions programs for global cryptocurrency trading platforms, including reviews of the adequacy of vendor solutions as well as policies and procedures.
- Trained employees at a major bank on new risk management processes and validated sustained implementation of new processes.
- Audited board and management governance of a bank’s relationships with its third-party customers and vendors, including BSA/AML, UDAAP, and fair lending risks.
- Performed a detailed review, analysis, and assessment of a hedge fund’s policies, procedures, systems, and controls to prevent the misuse of material non-public information by its employees and insider trading.
- Conducted an independent and holistic review, analysis, and assessment of policies and procedures related to governance and clearing activities at a major clearinghouse.
- Reviewed all aspects of enterprise risk management for a global financial institution to include culture and tone, governance and structure, reporting and management, control and mitigation, monitoring, risk measurement, and independent review functions.
- Analyzed risks and controls related to business processes at a major consumer lender to ensure compliance with CFPB regulations and identify deficiencies.
- Served as an independent compliance consultant pursuant to a FINRA enforcement action regarding a broker-dealer’s compliance with Blue Sheets and TRACE reporting.
- Conducted for an intermediate holding company a gap analysis of capital and liquidity risk management approaches, supporting executive-level responses to regulatory scrutiny regarding these areas.