Serving financial institutions navigating U.S. and cross-border regulatory obligations since 2009.
We advise financial institutions
on the compliance obligations
that define their regulatory posture.
Our work is consulting, not transactional. We stay close to each client, close enough to understand the business, not just the compliance file. Every engagement is assigned to a senior consultant who retains that relationship indefinitely.
Cross-border risk, AML program integrity, governance structure, and exam readiness: these are the obligations that define regulatory posture. We advise on all of them, as a single continuous relationship.
We advise financial institutions operating between the U.S. and Latin America, firms that face regulatory demands no single-market framework adequately addresses. Our practice was built for that gap.
Sound compliance is constructed before scrutiny arrives. We help firms maintain documentation, controls, and policies that reflect their actual operations, calibrated to their risk profile.
We build AML frameworks, sanctions controls, and EDD procedures calibrated to the client's actual exposure, specific to the firm and not derived from a checklist applied uniformly.
Every client works with an assigned senior consultant who knows their business. High availability and continuity are not service options; they are how we work.
Identifying a regulatory obligation is the beginning. We support the full operationalization: implementation, monitoring processes, evidence documentation, and internal adoption.
Annual compliance reviews, outsourced CCO services, SEC registration support, and exam preparation. Our RIA practice is the largest segment of our client base.
AML programs, supervisory controls, and FINRA compliance structures for domestic and international broker-dealers, including dual registrants with cross-border books.
Cross-border AML frameworks, EDD programs, BSA compliance, and regulatory risk assessments calibrated to the bank's jurisdictional exposure.
BSA/AML compliance programs, transaction monitoring procedures, and regulatory readiness protocols for MSBs across multiple jurisdictions.
Compliance infrastructure, governance frameworks, and the regulatory obligations arising from investment activities and complex client structures.
Subject-matter depth, regulatory interpretation, and practical execution support, working directly alongside CCOs, many of whom our consultants have been themselves.
"What holds under scrutiny is built before it arrives."
International Compliance Solutions
Since 2009, we have advised financial institutions operating at the intersection of two regulatory environments most firms treat separately. Our senior professionals have held positions at Merrill Lynch, Wachovia Securities, HSBC, Citibank, and Standard Chartered, across the U.S., Europe, and Latin America.
Our engagements are continuous and assigned, not project-based with changing teams. We adapt our work to how the firm actually operates, from program design and documentation through ongoing monitoring and exam preparation.
There are no account managers at ICS. Every client engages with a senior consultant who knows their business, their regulatory profile, and the specific matters that require attention. The quality of our counsel depends on that proximity.
Investment Advisers Act · Regulation S-P · Marketing Rule · Form ADV
Rules 3110 · 3130 · 4370 · 4511 · Reg BI · Dual Registrant Supervision
AML Program Requirements · SAR Obligations · CDD Rule · Beneficial Ownership
Sanctions Compliance · SDN Screening · GTO Compliance · PEP Programs
Foreign Corrupt Practices · FATCA Reporting · Cross-Border Tax Compliance
Jurisdictional Compliance Across Latin America, including Colombia · Panama · Venezuela · Mexico · Ecuador · Peru · Argentina · Uruguay · Chile
MSB Licenses · Credit Lending Licenses · State Registrations (RIA / Broker-Dealers)
Active expertise across the regulatory regimes relevant to financial institutions operating between the U.S. and Latin America.
Partial list. All client relationships held in strict confidence.
The SEC has proposed amendments that would revise small entity classifications under the Regulatory Flexibility Act for investment companies, investment advisers, and BDCs. Firms should review whether these changes affect their reporting and compliance obligations.
FINRA's proposed Rule 3290 addresses how registered investment adviser activities are classified and supervised within hybrid broker-dealer models. Dual registrants should assess potential operational and supervisory implications.
FinCEN has formally proposed postponing the investment adviser anti-money laundering rule effective date from January 2026 to January 2028. While the delay provides additional runway, firms are encouraged to continue program development.
ICS Insights
Periodic regulatory commentary.
ICS does not share subscriber information with third parties.
Our consulting model requires proximity to each client. We keep our client base selective; it is the condition of the service we provide.