It is the responsibility of each company doing business in any jurisdiction to ensure that its services, assets, and resources are not being used for illegal purposes. Failure to ensure compliance can result in severe legal sanctions. The U.S. Government, through the Department of the Treasury’s Office of Foreign Assets Control (OFAC), is actively targeting and designating individuals and entities for financing terrorism, corrupt business practices, and serious human rights abuses. We have noted that the application of sanctions to deter such behavior has been on an upward trend. OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) has more than 8,400 entities and individuals on it. This number has increased by 400 in 2020 alone.
Fara Group provides organization-wide Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) analysis to assess the integrity of the organization’s employees, clients and counterparties, as well as known business partners of its clients. Our auditing team and the methods they employ are specifically geared for projects in the world’s “hot spots” for AML/CFT. Through our experience in these jurisdictions, we bring a unique set of capabilities to the auditing process.
Fara Group mobilizes forward-deployed teams whose managers and analysts bring native language abilities and local knowledge. Our professionals are familiar with the inherent legal and political risks specific to frontier markets. Over half of our staff are native Arabic speakers and located in the MENA region, so we are able to quickly employ professionals with targeted language or industry skills as required by specific projects.
Fara Group is highly proficient in processing large quantities of unstructured data. Particularly for financial audits, this allows us to not rely solely on structured information provided by an institution’s core systems. We employ teams of native speakers to process and organize extensive volumes of unstructured data into a format that can be readily analyzed. Our experience has included dealing with poor quality, hand-written financial records.
Augmented auditing methods
Fara Group combines international best practices with a local understanding of criminal behavioral trends. Our account auditing checklists comply with FATF and OFAC guidelines and include additional items that help reveal deceptive practices unique to the institution or the country in question. We employ data science techniques used by the FBI in spotlighting suspicious account behavior and tracing financial flows across banks and national jurisdictions.
Fara Group offers a forensic-level analysis for firms who are concerned about potentially toxic transactions in their records. We define the scope of the problem and formulate a plan to remedy it. We pull information from a plethora of datasets, including proprietary databases used by OFAC and FinCEN. Where needed, we employ confidential human sources to validate and enrich our analysis.
Fara Group understands the full spectrum of risks to the client and the auditing party and takes mitigative measures to protect them. The less regulated nature of “hot spot” jurisdictions where we operate elevates auditing risks originating from deliberate misstatements and omissions, which may present a risk to anyone associated with the audit process. We anticipate these and respond.