Jennifer Flannery

Jennifer joined Grant Thornton from a Big 4 Regulatory and Financial Crime Advisory team. She has over 12 years of legal, compliance and financial services industry experience. Jennifer specializes in engagements addressing Anti-Money Laundering (‘AML’) and economic sanctions regulatory and compliance matters. She is a qualified Solicitor and is licensed to practice is the UK and Ireland.

She has worked in London, New York and Ireland advising clients on enforcement actions pursuant to compliance with Bank Secrecy Act (‘BSA’)/ USA Patriot Act and Office of Foreign Assets Control (‘OFAC’) Act rules. Jennifer has led and managed a number of AML engagements including the following:

KYC program design and uplift - Evaluation of KYC program elements across governance, Customer Identification Program (‘CIP’), CDD, Customer Risk Rating (‘CRR’) and operating models to achieve sustainable Business as Usual (‘BAU’) operation. 

CDD/ ESS standards - Drafting of CDD and EDD standards including policies and procedures and requirements based on regulatory requirements, regulatory guidance and industry practice.

KYC remediation - Evaluation of client KYC files to assess whether documentation collected satisfies KYC standards and requirements.

Regulatory Response & Corrective Action plans - Drafting detailed responses for submission to the regulator outlining BSA/AML/OFAC program areas requiring enhancement in order to satisfy enforcement action. 

Transaction Monitoring – Delivery of AML transaction monitoring and sanction investigations including developing investigation protocols associated with the identification of unusual behaviour and consideration of Suspicious Activity Report (‘SAR’) filing.