In 1970 I migrated from London to Nassau, having spent 14 years in banking, trust and estate administration and investment management. In Nassau I spent 9 years with BankAmerica Trust, (Senior Trust Officer), 2 years at CIBC Trust, (Managing Director) and 18 years at Leadenhall Trust Company, (Managing Director), from which I retired in 2000.In 2004 I was invited to join The Winterbotham Trust Company as Compliance Officer and subsequently was appointed MLRO. Engaged to provide compliance management and supervision, I worked closely with the bank’s in-house IT team on the development of risk management procedures, risk assessments, customer information management and transaction control processes. We established protocols for the reporting required by FATCA, CRS and local CESRA and BOSS reporting. I revised and created operational and policy manuals for all KYC onboarding and transaction management processes and established Ethics and Corporate Governance manuals. As the bank expanded, my responsibilities extended to Hong Kong, Cayman Islands and Puerto Rico. I was registered as Compliance Officer and MLRO in Hong Kong and the Cayman Islands. In that capacity I engaged with Financial Intelligence Units, local regulators and correspondent banks and studied the statutes, regulations and guidelines in those jurisdictions.