Specialties
Model Governance
Data Integrity
Model Output and Performance
Helping you meet regulators’ demands for independent AMS model reviews
We bring the people and know-how to conduct rigorous, risk-based AMS model validations to assess how well your model governance, data integrity, and parameter thresholds adhere to regulatory guidance.
Conducting an AMS model validation is both an art and a science.
Hundreds of banks and credit unions view us as trusted artists and scientists and count on us to bring insightful regulatory intelligence during AMS model validations.
With real-world experience as former bankers, we understand the effect of increased regulatory pressure on your team. Relying on plug-and-play settings, for example, is a path to frustration, and we know how it feels to be overwhelmed by alerts and struggle to discern what warnings to heed or ignore.
Members of our team have done everything from examining data integrity and its quality and conducting “above the line” and “below the line” testing to assessing a model’s design and how well it’s tailored to your risk profile.
We also bring a solid track record in understanding the quirks of various AMS solutions in the marketplace and performing system validations on them.
Our assessments consider both IT and BSA perspectives, and we focus on three areas:
- Model governance
- Data integrity
- Model output and performance
Throughout each engagement, we communicate with you to keep you informed on our progress and findings. At the conclusion, our exit meeting and written report document our scope, methodology, findings, and recommendations.
Once our AMS Validation is complete, you can be confident that your model is sound and meet examiners’ escalating expectations.
TCA gives you A Better Way to gauge whether your AMS model meets its objectives and protects you from money-laundering risks.
Key Deliverables Include:
- Testing administrative controls, data import, and data integrity.
- Reviewing system parameters to be sure they’re functioning correctly and identifying suspicious activity.
- Ensuring that your model has been calibrated to your bank's risk profile.
- Analyzing exams, reviews, and monitoring reports to trace the resolution of issues requiring corrective action.
- Providing exceptional service that respects your time.
AMS Insights
FinCEN Issues New Type of Special Measure
As part of a supplemental appropriations bill passed in September 2024, Congress enacted the FEND Off Fentanyl Act. Section 2313(a) granted the U.S. Treasury the authority to impose special measures against financial institutions suspected of funneling illegal proceeds derived from the illegal manufacture, transportation, and sale of fentanyl. TCA – A Better Way!
Focus on Fraud and Suspicious Activity Reporting
A big focus of conversations in the AML/CFT world recently has focused on the increase in fraud schemes as a mechanism to generate illicit funds which are then ultimately laundered. Financial institutions of all sizes are feeling the impact of fraud schemes targeting their customers and their bottom lines. TCA – A Better Way!
What should AML Programs Learn from Consent Orders?
AML/CFT Consent Orders…AML/CFT Regulatory Fines. These are two phrases that compliance professionals all hear, and hope will never apply to their financial institutions. Yet these actions do occur frequently enough to make one wonder -what steps might be taken to avoid them? TCA – A Better Way!
Dodd Frank Section 1071 Small Business Data Collection Rule Postponed
On June 18, 2025, the CFPB published an interim final rule effective on July 18, 2025, postponing the effective date of Regulation B implementation of the Section 1071 Small Business Data Collection Rule. The summary states: In light of court orders in ongoing litigation, the Consumer Financial Protection Bureau (CFPB or Bureau) is amending Regulation […]
FinCEN Advisories and Key Terms When Filing SARs
FinCEN issues public and non-public advisories to financial institutions in order to help educate them in detecting, preventing, and reporting potential suspicious activity to FinCEN. TCA – A Better Way!
What are MDI’s and the benefits of partnering with one?
Do you ever feel hesitant to engage with organizations in your community because you are unsure if the activity will qualify for CRA? You are not alone. Inconsistencies among the agencies as to what qualifies as CRA eligible activity can cause confusion and make discerning worthwhile partnerships from not-so-worthwhile partnerships that much more difficult. In […]
