Performed third line testing of BSA/AML areas for large International Bank. Functions included but were not limited to design and operational effectiveness testing, development of testing scripts/testing program, thematical roll-up of findings, and stakeholder vetting.

Worked as Financial Crimes Program subject matter expert in an advisory role in order to provide guidance on the development and implementation of automated governance programs for Banks, Fintechs, Cryptocurrency Exchanges, and Money Service Businesses.

Reviewed International and Domestic Wire Payments before their release in order to ensure compliance with the Travel Rule, Internal Bank Policy, and OFAC/Sanctions Regulations.

Served in Monitorship capacity for large Interational Bank performing full review of Sanctions/OFAC Program. Areas covered included but not limited to, Transaction Screening, Customer List Screening, Vendor Screening, OFAC Risk Assessment, and Trade Finance.

Performed Monitorship role which entailed a full BSA/AML and OFAC/Sanctions Program review for a large Broker Dealer which in response to FINRA and CFTC regulatory mandates. Areas covered included but not limited to, AML Transaction Monitoring for both money movement and security trade transactions, new product approval which included the rollout of cryptocurrency, BSA/AML Risk Assessment, AML Coverage Assessment, Sanctions Name Screening, and Enhanced Due Diligence.

Performed numerous roles as project manager on several different engagements involving many aspects of BSA/AML, OFAC/Sanctions, Fraud, and Anti-Bribery and Corruption, including but not limited to, KYC remediation and design of KYC risk rating models, Transaction Model Validation, Transaction Surveillance Investigations, Transaction Surveillance Audit design and testing, OFAC Audit design and testing, Governance, and Trade Finance Audit design and testing. A brief description of some of these projects follow below. Served in a Monitorship capacity for five large International Banks and a Money Service Business in order to conduct a full review of the BSA/AML and OFAC Programs pursuant to Regulatory Orders. Areas of coverage include but not limited to Transaction Monitoring and SAR Reporting, Subpoenas, Information Sharing (314(a), and 314(b)), KYC, Vendor Management, Management Information Systems, 311 Special Measures, Record Retention, Governance, AML Coverage Assessment, and BSA/AML Risk Assessment.Performed BSA/AML and OFAC/Sanctions program reviews for Fintech Companies. Lead team handling the AML Transaction Monitoring and Fraud Interdiction program review for a Major International Money Service Business (MSB). Review was conducted as part of a three-year Monitorship, which included AML and Fraud Typology coverage, tuning, as well as a review of the alert, case and SAR design and operating effectiveness. Developed and drafted Financial Crimes Compliance Program for a large International Bank and developed Financial Crimes Action Plan for remediation efforts related to a Cease and Desist Regulatory Order. Developed program for KYC uplift and vendor management and procurement. Lead team handling large FCC Internal Audit Validations for a large International Bank in the areas of Transaction Monitoring, KYC, and Management Information Reporting.

Worked on AML LookBack investigation for a large Colombian based bank requiring complete Spanish fluency in reading and analyzing all documents and transactions. Functions included the Quality Assurance role pertaining to the analysis and investigation of potentially suspicious financial transactions in international transfers within the correspondent banking sector. Focus was on red flag items related to OFAC sanctions and violations, geographical relationship between parties, legitimate business purpose, transaction frequency, high dollar amounts, circular, pass through, IVTS, nesting and structured transactions.

Worked on remediation KYC project of vetting, research and reporting of customer information and ownership structures in compliance with the USA PATRIOT Act Section 312 (Due Diligence and Enhanced Due Diligence) and Section 326 (CIP requirements). Involved the application of my legal, financial and accounting expertise to investigate and determine the beneficial owner and ultimate beneficial owner (UBO) structures for foreign financial institutions, individuals, trusts, hedge funds, corporations, LLC’s and private investment vehicles. Further functions included examining the ownership structure on clients in order to better understand and make recommendations regarding their current and potential risk rating relevant to other factors such as geography, industry type, PEP’s, media findings and OFAC sanctions and violations. Also, functioned in the capacity of Quality Assurance whereby prior analyst’s work was reviewed for deficiencies.

Worked on LookBack Anti-Money Laundering (AML) transaction monitoring project in the correspondent banking sector. Functions included the Quality Assurance, analysis and investigation of potentially suspicious financial transactions in correspondent banking, and the drafting of related SAR’s (Suspicious Activity Reports). Focus was on red flag items related to OFAC sanctions and violations, geography of the parties (Originator and Beneficiary), geographical relationship between parties, legitimate business purpose, transaction frequency, high dollar amounts, circular, pass through, nesting and structured transactions. Also performed review and quality assurance feedback on investigations conducted in India.

Worked on two projects under the FDIC Receivership Assistance Contractor Program dealing with the closing of failed banks. One project I was the investigator who handled the interviewing and write-ups of key bank executives, mortgage review, analysis of board minutes, personal financial statement review and all related investigative matters dealing with the bank failure. On another project I was part of the Proforma team that ensures all the assets on the books of the failed bank are properly stated, and that all the appropriate accounting treatments are met to transfer assets to the acquiring bank or the FDIC as Receiver.

Worked on KYC uplift performed pursuant to regulatory requirement that the Investment Firm become a registered Bank Holding Company. Functions included Know Your Customer (KYC) process of vetting, research and reporting of customer information and ownership structures in compliance with the USA PATRIOT Act Section 312 (Due Diligence and Enhanced Due Diligence) and Section 326 (CIP requirements). Entailed in depth analysis and investigation to determine the beneficial owner and ultimate beneficial owner (UBO) for foreign financial institutions, individuals, trusts and private investment vehicles. Performed Quality Assurance Review of analyst’s work, and reviewed Spanish documents and telephone client account contacts requiring Spanish fluency.

Functions included the Know Your Customer (KYC) process of vetting, research and reporting of customer information and ownership structures in compliance with the USA PATRIOT Act Section 312 (Due Diligence and Enhanced Due Diligence) and Section 326 (CIP requirements). This entailed an in depth analysis and investigation to determine the beneficial owner and ultimate beneficial owner (UBO) for trusts, public/private entities and natural persons. Worked with Spanish documents requiring English translation.

Worked as consultant for retail bank involving the internal audit of mortgages and credit leases. Functions included the full audit of residential and commercial mortgages and credit leases against existing policies and procedures, and the drafting of an audit report.

Worked on an Anti-Money Laundering (AML) LookBack project. Functions included quality assurance and review of SAR’s (Suspicious Activity Reports) and NFA (No Further Action) reports. Analyses and investigation was accomplished by using Excel to sort, filter and query red flag items pertaining to geography of each individual, geographical relationship between parties, legitimate business purpose, transaction frequency, high dollar amounts, circular, pass through, nesting and structured transactions.

Worked on an Anti-Money Laundering (AML) LookBack project. Functions included transaction monitoring via the analysis and investigation of potentially suspicious financial transactions in correspondent banking, and the drafting of related SAR’s (Suspicious Activity Reports). Also performed quality assurance and review of SAR’s and case closings drafted by other investigators. Analysis and investigation was accomplished by using Excel to sort, filter and query red flag items related to OFAC sanctions and violations, geography of the parties (Originator and Beneficiary), geographical relationship between parties, legitimate business purpose, transaction frequency, high dollar amounts, circular, pass through, nesting and structured transactions. Also performed analysis that focused on researching and analyzing the existence and use of shell companies as they relate to AML. Worked with Spanish documents requiring English translation.

Worked on accounting and legal compliance project entailing the review and analysis of mortgages and Mortgage Backed Securities (MBS). Worked on SOX design project dealing with mortgage lender and loan compliance. Worked on regulatory response to Consent Order issued by Office of Federal Housing Enterprise Oversight (OFHEO) involving the drafting of policies and procedures within the mortgage sector.

Performed securities investigations related to Market Timing and Late Trading pursuant to a New York Attorney General mandate. Analyzed and reported on information pertaining to SEC compliance within the broker and trading sector. Performed reviews relating to broker dealer compliance under the Securities Act of 1940. Acted in the role of quality assurance dealing with the review of investigative findings and write-ups that were to be presented to the SEC. Managed project overseeing 35 attorneys that entailed the management of data, coordinating and scheduling of project completion dates and the monitoring of workflow.