K2 Intelligence acts as advisors to governments, companies, and high-net-worth individuals; our clients frequently include public entities and private companies in a variety of sectors, including energy, mining, real estate and construction, education, and technology, as well as hedge funds and private equity firms, law firms, financial institutions, and private and sovereign clients seeking to recover assets.
- The U.S. Federal Reserve Board (FRB) appointed K2 Intelligence as an independent consultant to conduct a historical transaction review of one of the world’s largest financial institutions pursuant to a cease and desist order stemming from various anti-money laundering and Bank Secrecy Act compliance deficiencies. This engagement involves deploying an integrated team of compliance experts, former regulators, and forensic accountants to review over 140 million foreign correspondent banking transactions, in order to determine whether suspicious activity was properly identified and reported in compliance with applicable AML/BSA reporting regulations. The team will also prepare suspicious activity reports (SRAs), as necessary, and present a written report to the FRB at the conclusion of the review to detail our findings. This is an ongoing matter.
- The Federal Reserve Bank of New York has retained K2 Intelligence to conduct a historical transaction review of a global financial institution resulting from a federal examination that disclosed significant deficiencies relating to the New York branch’s risk management and compliance with applicable federal and state laws, rules, and regulations relating to anti-money laundering (AML) compliance, including the Bank Secrecy Act (BSA). The K2 Intelligence team will determine whether suspicious activity involving high risk customers or transactions were properly identified and reported in accordance with applicable suspicious activity reporting regulations prepare and deliver a report of our findings to regulators. This is an ongoing matter.
- The New York State Department of Financial Services (NYDFS) retained K2 Intelligence to act as the independent monitor for a global financial institution pursuant to the consent order entered into between the institution and NYDFS. Per the consent order, K2 Intelligence has been tasked with conducting a comprehensive review of the institution’s BSA/AML and OFAC compliance programs, policies, and procedures now in place that pertain to or affect activities conducted by or through the financial institution for compliance with applicable requirements, laws, and regulations. The order also requires K2 Intelligence to conduct a historical transaction review for a time period of three years. This is an ongoing matter.
- We were selected by the U.S. Federal Reserve Board and international regulators to serve as the independent consultant responsible for performing an annual review of OFAC compliance policies, procedures, and remedial actions at one of the largest multinational financial institutions in the world, pursuant to the terms of a global consent order entered into by the institution stemming from violations of U.S. sanctions laws. Over the course of the engagement we will continue to monitor and assess the development of the institution’s OFAC compliance program, validate the implementation of our recommendations, and report our findings to the institution as well as the relevant regulatory agencies. This is an ongoing matter.
- A financial institution based in the Middle East chose us to assist its U.S. operations with both compliance and operations support. We provided support pertaining to the client’s governance and operations functions and its AML compliance program including, but not limited to, management assistance with day-to-day operational support, file review, writing or editing bankwide operating policies and procedures, and transaction testing. K2 Intelligence also conducted a situational assessment of the compliance program, reviewing policy and procedure documents and conducting walkthroughs and interviews with bank employees and later furnishing recommendations based on regulatory requirements and industry standards and best practices. The K2 Intelligence team piloted a comprehensive activity monitoring system scenario-tuning exercise to help create efficiencies and eliminate redundant alerts within the monitoring system. Our team also assisted the bank with transaction monitoring and OFAC alert clearing support.
- Our Regulatory Compliance practice completed work on what has become one of the largest transaction lookbacks in history. Conducted under the supervision of the U.S. Federal Deposit Insurance Corporation (FDIC), a leader in financial services turned to our team, composed of the most highly trained AML professionals in the industry, to employ the latest real-time financial monitoring technology on more than 1.5 billion transactions.
- K2 Intelligence AML professionals with foreign correspondent transaction experience are working closely with a prominent global financial institution, assisting the institution with the reduction of accumulated transaction monitoring alerts identified by its suspicious activity monitoring system. In addition, K2 Intelligence is tasked with reviewing alerts in a test environment while conducting above- and below-the-line testing. Our team has also assisted the institution with a review of accumulated Know-Your-Customer (KYC) memos related to higher-risk clients.
- K2 Intelligence provides virtual third-party financial intelligence unit (FIU) services to a midsize New York–based commercial bank in connection with its prepaid card product offerings, clearing alerts, documenting dispositions, and working with the bank’s program managers to gain additional information on cardholders and file suspicious activity reports (SARs) when necessary. K2 Intelligence also works closely with the bank’s compliance team to identify unusual activity and to tune parameters and thresholds in order to focus on those transactions with the highest indicia of suspicion. In addition, we provide monthly key performance indicator reports that are distributed to the bank’s management.
- K2 Intelligence helped virtual-currency exchange clients Cameron and Tyler Winklevoss launch Gemini, a Bitcoin exchange. The K2 Intelligence team helped the client obtain licensing approval from the New York Department of Financial Services, which enabled tthe Gemini exchange to open for trading, and later helped the client receive authorization to operate as a chartered LLC trust company. K2 Intelligence AML professionals crafted AML and KYC policies and also conducted AML/Combating Financing of Terrorism (AML/CFT) training for Gemini.
Investigations and Disputes
- K2 Intelligence completed a forensic investigation on behalf of the International Boxing Association (AIBA), the worldwide governing body for the sport of boxing. Our investigation covered the management of both AIBA’s and the World Series of Boxing’s (WSB) finances. K2 Intelligence was also mandated to investigate financial issues and allegations of mismanagement related to the former AIBA president’s office.
- K2 Intelligence was selected by New York’s Empire State Development Corporation as the integrity monitor for the Javits Center Expansion and Moynihan Train Hall projects, a five-year assignment to protect New York State’s investments of more than $3 billion. As the integrity monitor for these two iconic New York City projects, K2 Intelligence will assist in providing necessary payment and compliance oversight as well as construction monitoring.
- We provided data analytics litigation support to Irving H. Picard, the SIPA Trustee for the liquidation of Bernard L. Madoff Investment Securities LLC (BLMIS), as well as for court-appointed counsel. We utilized cutting-edge technology and investigative analysis to help maximize the recovery of funds to be distributed to the victims of the fraud, and compensation for losses from this unprecedented Ponzi scheme.
- In a joint effort between K2 Intelligence’s Investigations and Disputes practice and its Cyber Defense practice, we worked with a law firm to provide data breach litigation support in a multidistrict class action accusing one of the country’s largest health insurers of failing to properly encrypt its data and prevent a massive data breach affecting 80 million people.
- The Association of National Advertisers (ANA) turned to K2 Intelligence to help shed light on certain non-transparent practices in the U.S. media-buying marketplace. The K2 Intelligence study, publicly released 7 June 2016, detailed evidence of the existence of non-transparent business practices, including cash rebates to media agencies, in a sample of the U.S. media ad-buying ecosystem. Within that sample, such practices were found to be pervasive, with senior agency executives being aware of, and even mandating, some non-transparent business practices.
- We have conducted ground-breaking investigative work to help uncover gun sellers illegally engaging in business without a license for Everytown for Gun Safety, a movement of Americans working together to end gun violence and build safer communities.
- The Moreland Commission to Investigate Public Corruption tapped us to assist it in the investigative effort to probe systemic corruption and the appearance of such corruption in state government, political campaigns, and elections in New York State.
- We led the first large-scale deployment of project oversight integrity monitors in a disaster recovery setting. At Ground Zero, our integrity monitors were engaged by the City of New York and were involved at every phase of the World Trade Center recovery effort, from contract award to on-site activity.
- The retail and commercial bank of a global financial group engaged us to conduct an investigation into apparent related-party transactions. We were later asked to broaden the scope of the investigation to include an internal forensic investigation focused on the details of related-party transactions of officers, directors, and significant shareholders. We also investigated the existence of potential conflicts of interest associated with certain portions of the business; the existence of potential misuse of corporate resources by certain key officer; and the existence of a culture of noncompliance at the institution.
- K2 Intelligence provides due diligence and risk intelligence services for the world’s largest technology investment fund to evaluate potential investments for their multibillion-dollar, global portfolio, which includes cutting-edge industries such as robotics and artificial intelligence. Our team also works with the fund to create a consistent risk evaluation and management infrastructure for their portfolio of their ongoing investments.
- K2 Intelligence currently provides business intelligence support to one of world’s largest sovereign wealth funds and its globally based portfolio companies, on engagements connected to pre-investment due diligence, partner due diligence, and senior executive profiling, enabling our client to have more leverage in deal negotiation and achieve optimal investment outcomes.
- K2 Intelligence conducted an independent investigation on behalf of a leading university in the United States into a range of suspicious donations related to the college admissions scandal known as “Varsity Blues.” K2 Intelligence’s multidisciplinary team conducted a thorough and targeted investigation consisting of forensic review and analysis of university data and electronic devices, review of relevant records documentation, and forensic investigation into the financial records and processes within the university, especially as they related to donations and distributions of funds to the athletic departments. Our findings were presented to the board of trustees and were included in a report that was voluntarily presented to the authorities. Based on the findings, we made recommendations to the university pertaining to its policies and procedures in order to tighten the controls over the admissions process.
- On behalf of a major professional sports league, K2 Intelligence conducted due diligence and background investigations of a syndicate of investors looking to purchase a professional sports team. Based on our team’s findings, several of the syndicate investors were removed from the eventual purchase.
- K2 Intelligence conducted an investigation for a major pharmaceutical and life sciences company into the manufacture and distribution of counterfeit surgical sutures. The investigation spanned three continents and ultimately led to India where, in collaboration with local law enforcement, our team uncovered and shut down the manufacturing of the counterfeit product and worked with local authorities to have the perpetrators arrested and sanctioned.
- K2 Intelligence was hired by high-profile individuals and executives to investigate and identify the perpetrator of an impersonation scam, known in the media as the “Con Queen of Hollywood.” The impersonation scam includes luring entertainment industry professionals, such as make-up artists and hairdressers, photographers, and stunt professionals, to Indonesia under the false pretense of scouting potential projects and convincing them to pay all travel and on-the-ground expenses to local drivers and other intermediaries.
- K2 Intelligence was retained by the prosecutor general of the anticorruption agency of an Asian country to conduct an asset trace and recovery investigation focused on high-ranking members of the two former presidential administrations suspected of selling off state assets for inadequate sums and benefiting from the sales through the receipt of kick-backs. To date, our globally based team of investigators has located approximately $150 million worth of assets across several foreign jurisdictions held by the former administration officials through proxies. The team also worked in collaboration with local authorities in the various countries to freeze and repatriate the assets to back to the home country.
- K2 Intelligence was engaged by a large U.S. company to review and update the anti-bribery/anti-corruption policies and procedures in place at one of the company’s overseas subsidiaries. In the course of the review, the K2 Intelligence team identified indications of possible corruption, leading to an internal anti-bribery/anti-corruption investigation performed at the direction of and in coordination with the company’s in-house and external counsel. The investigation ultimately included dozens of on-site interviews, document review, and review of electronic communications among key employees. Since the conclusion of the investigation, K2 Intelligence has performed annual anti-bribery/anti-corruption reviews to monitor improvements in the subsidiary’s policies, procedures, and internal controls—including third-party due diligence, procurement, and third-party contracts—as well as status of implementing K2 Intelligence’s recommended remedial measures.
- We conduct due diligence on behalf of some of the world’s largest asset management firms, including hedge funds, private equity firms and sovereign wealth funds, investigating and assessing investment opportunities and their related legal, reputational, and political risks across a variety of industry sectors including technology, healthcare, real estate, sports and entertainment, consumer goods, and manufacturing, among others.
Private Client Services
- K2 Intelligence was engaged by March For Our Lives, a movement created by, inspired by, and led by the students of Parkland High School to provide security planning and protection work for the students beginning with the initial March 2018 Washington, DC event and continuing through the U.S. midterm elections in November 2018. We also provided 24/7 physical protection and security logistics for the March For Our Lives: Road to Change summer bus tours to get young people educated, registered, and motivated to vote. This work included the U.S. National Tour as well as the Southern Tour all around the State of Florida.
- A professional sports franchise engaged K2 Intelligence's Private Client Services practice to complete a top-to-bottom organizational security assessment of the franchise and its home arena, later helping the franchise to implement procedural and public safety improvements and to vet and hire its new chief security officer.
- We provided strategic advice and online threat monitoring related to films and talent concerned with activist or political backlash for a major American film studio and other entertainment clients in Hollywood, including identification and remediation of false reviews intended to damage the success of projects.
- To protect the privacy of our client, a major singer/songwriter targeted by a hacker who had gained access to sensitive accounts, including a social media page followed by more than a million fans, K2 Intelligence investigated and identified the hacker, successfully de-anonymizing and engaging in person with the individual in South America to stop the attack, inventory the data accessed, and remediate the effects of the intrusion.
- We unwound a near-million-dollar insider embezzlement from a successful hedge fund to repatriate a significant portion of stolen funds and to strategize with stakeholders to ensure the event did not publicly damage the reputation of the client.
- Recent engagements include assisting high-net-worth and high-profile individuals and families, celebrities, and C-level executives with a broad range of security services, including those related to physical security, cyber threats, privacy and reputation, and safety in public spaces, as well as fraud investigations and art authentication and recovery.