The USA Patriot Act has brought a new deminision to international banking, affecting not only domestic banks but all international banks whose transactions cross U.S. borders.

The Morley Group has been deeply involved in USA Patriot Act issues since the inception of the Act, both in the U.S. and in Latin America. Our practice has given us an appreciation of the many complex issues the Act brings to international financial institutions.

We have accordingly designed a BSA/AML/OFAC Assessment process that evaluates financial institutions' compliance with the many detailed requirements of the BSA, OFAC, and the USA Patriot Act. Our Assessment not only provides our clients with a detailed report on the adequacy of their compliance, but also gives the clients comprehensive road maps that will take them to complete compliance with each requirement of the BSA, OFAC, and the USA Patriot Act. We are, of course, fully equipped to assist our clients in bringing their institutions into full compliance as well.

The Morley Group has also proven very adept at conducting institution-wide risk assessments. Our risk assessment go substantially beyond the minimum criteria set forth in the FFIEC Manual. We not only take into account the institution's mitigating factors, but suggest additional mitigation procedures as well. We generally conduct a complete risk assessment prior to conducting a BSA/AML/OFAC Assessment.