For certain customers, there may be a need to examine their payment history. These look-back reviews may lead to a disclosure to OFAC or other regulatory body. In this highly sensitive and confidential area, we are able to:

• Work closely with in-house and external counsel as well as compliance teams to manage process.

• Extract comprehensive payment information from data warehouses and archives.

• Conduct deep forensic reviews and establish definitively if a payment was ultimately paid by looking at the individual legs of a payment.

• Use a controlled process with inherent completeness and accuracy checks.

• Assemble coherent narratives as to why, where, when and how a payment was made.

• Design, build and operate VSD processes for investigating and reporting on breaches.

• Produce comprehensive self-disclosure packs for review and submission to regulators.