Project Baur


KRyS Global was engaged by the regulator to serve as independent examiner and assist in the investigation of numerous accounts and the analysis of the AML policies of a licensed bank where certain customers had been the subject of money laundering allegations. KRyS Global was required to conduct its analysis under a very tight deadline, against the backdrop of intense public scrutiny and competition for the licensee’s limited resources.


Using a focused and methodical approach, KRyS Global carried out a detailed comparison of the bank’s existing AML policies and procedures with the in force regulation at the time identifying deficiencies and proposing recommendations.

We assessed whether the bank had complied with its stated AML policies and procedures in respect of the customers in question.

Lastly, we carried out an assessment on a sample testing basis covering tens of thousands of transactions to identify any connected activity or other possible money laundering.

Value Added:

In addition to delivering a comprehensive report that was praised by the regulator, the team kept the regulator apprised of their progress and issues being identified through regular meetings and update calls, to ensure the final report satisfied all of the regulators concerns.