• In charge of i) Policies and Procedure updates and oversight bank wide ii) Risk Assessment iii) Training iv) RFI oversight iv) PMO Oversight and part of the bank's leadership team.• Program oversight and support the bank’s Regulatory Compliance and CCO’s responsibilities relating to ensuring an effective Bank Secrecy Act/Anti- Money Laundering/OFAC Compliance Program that is following industry best practices, regulatory guidance, and requirements. • Ensure the guidance, relevant policies, procedures, and processes to comply with all applicable BSA/AML/OFAC rules, regulations, and regulatory guidance; is effectively being implemented. • Monitor the performance of the BSA/AML/OFAC Compliance Program and related activities on a continuing basis, providing guidance to senior management /BoD on appropriate steps to improve its effectiveness and keeping management informed. • Facilitate remediation of BSA/AML/OFAC audit and examination findings and ensure relevant processes are updated and staffs are trained to prevent future violations. • Establish project governance Structure.• Provide Management Reports.• Prioritize projects as per strategic business objectives. • Plan and schedule resource efficiently.

AML and Sanctions lead and project manager (PMO) within the firm’s Financial Crime, Fraud & Investigative Services advisory practice providing financial crimes subject matter expertise and services for multiple types of financial institutions including MSBs, Banks, FinTech/Payment & Virtual currency companies. Advisory services provided include: FC-Risk Management readiness and framework, Export controls and dual use goods, Part 504 Certification readiness, Model validation & Conceptual soundness, Automation, Sanction screening, Policies & Procedures, Transaction monitoring assessment, Automation, Risk Assessment, CIP/KYC/CDD/EDD, Project Management, Governance, KPI & KRI assessment and Trade Finance remediation.

Sr. BSA Officer, Commodities Business Center 12/2018- PresentResponsible for all compliance matters regarding Bank of China’s US Commodities Business Center including:• Managing & approving all aspects of on boarding new corporate accounts.. • Complete CIP and KYC requirements coverage.• Managing CBC Associates & interns regarding the entire KYC refresh process and life cycle.• Training and expressing new requirements to the department.• Main point of contact for all requirements regarding FircoSoft Trust relationship management screening.• ABAC Point of contact within the Commodities Business Center.• Manage monitoring/screening all stages of an LC life cycle from any form of financial crimes.Deputy Head of Sanctions 11/2017 – 12/2018Under the OCC Consent Order, responsible to manage and be the responsible person for COAP deliverables of the entire Sanctions program & governance activities including:• Oversee five sanctions teams, managers and contractors (up to 45 personnel) under the US Sanctions Program Office, ensuring high quality coverage involving: a) Operations (live screening); b) Filtering systems; c) ‘PCAT’: Policies, Communications, Advisory & Training; d) Administration; and e) Investigations.• Successfully managed completion of FircoSoft (continuity) implementation project, working closely with the PMO ensuring key features and algorithms are completely assessed, addressing the bank's risk appetite.• Identify potential issues and communicate with the Chief Compliance Officer, Sanctions Head & Chief Risk Officer to provide solutions and proposals for immediate remediation.• Ensure team managers maintain a correspondence with OFAC for sanctions guidance.• Ensure OFAC risk management advisory and complex investigations are conducted properly.

AML/BSA/Sanctions MIS Project leader & Architect 10/01/2016 – 2/28/2017 Responsible to assess AML/BSA/OFAC MIS reports & infrastructure of this institution’s foreign US based agency in NY under regulatory examination Assess & make recommendations to improve bank’s customer risk assessment methodology & reports Recommended the immediate implementation of institution’s Trade Financing booking system with list of full sanction seaports. Provided a dozen Trade Finance AML MIS report-list and RDDsSenior Consultant 06/29/2016 – 9/29/2016Leading consultant interacting with senior management and executives at this European financial institution in New York currently under scrutiny. Responsibilities include: Taking ownership of gathering all documents relevant to this bank’s transaction monitoring system (Detica) and drafting a mandated Functional Specification Document (FSD) Evaluating/Proposing improvements to the bank’s surveillance analysis system on both AML & Sanctions issuesSenior Consultant/Bank Examiner 04/15/2016 – 05/18/2016 Leading consultant guiding the AML-technology team examining a number of financial institutions in the Balkans, for AML typology deficiencies & Sanction screening list-assessment, across all products institutions offer

Trade Finance AML & OFAC Program Director Oct, 2013 – Apr, 2016 Introduced a comprehensive AML & Sanctions Trade Finance transaction monitoring frame-work ever developed for commercial banks, providing full coverage of regulatory requirements in Trade programs Chief architect, providing 25 Trade finance-based AML monitoring scenario rules and 52 Trade-AML reports pertaining to Trade Finance transactions. All captured form international bodies such as FFIEC, FCA, FinCEN, NDIC, FATF, ICE, Wolfsberg, APG on TBML, OFAC, BSA and more  Responsible to lead a team of developers, data-architects and sales engineers to develop a unique documentary-credit based AML monitoring & reporting software designed by me at our partner’s (IBI) offices Demonstrated this AML-Trade monitoring software to the directors of FinCEN, OCC and ICE-TTU Conducting presentations, workshops, working groups, seminars & webinars on this new trade innovation (Omni-Trade) to the CCOs, Heads of Trade, AML & OFAC of major US & foreign financial institutions Key role in BAFT’s AML workshop, focused on Trade transaction monitoring red flag consolidation, introducing two new Trade red flags MSB Rule validation – Senior Advisor to the Monitorship Sept, 2014 – Jan, 2015 Advisor to the court assigned Monitor, on validation of a major US- MSB’s money transfer AML & Fraud rules. Validation is to ensure they are in compliant with BSA and FATF-MSB guidelines and provide recommendations for improvements to the designated Monitorship.

Not an employee of BAFT, but contributed towards the 16 published Trade red flags.

• Analysis of AML-KYC business requirements and conversion into technical solutions utilizing MS Access database and Metrics for bank’s GTS• Preparation of Management Information reports and /or automation of the production of reports regarding KYC & SAR cases utilizing Access database queries, reports and MS Excel (Matrices)• Performing data auditing and validation on bank’s global transactions including Correspondent Banking• Analysis and manipulation of large data sets to prevent risk under Accounts Intelligence Unit (AIU)• Updating database with ad-hoc information received• Managing two consultants and a team in Mumbai regarding exception reports• Liaise between Compliance and Technology departments to retrieve and send data• Production of metrics for countries serviced by AIU and provide to global AIU on a regular basis• Ongoing maintenance and development of AIU workflow tool and consolidation tool• Adhere to Citigroup and regulatory policies and procedures with regards to KYC\CADD

• Responsible for drafting SARs as well as 1st and 2nd supplemental SARs in accordance with Financial Crimes Enforcement Network (“FinCEN”) procedures.• Utilization of Norkom system to perform transactions surveillance of wire transactions.• Trained Case managers in SAR drafting & utilizing Norkom.• Use of search utilities such as Lexis Nexis, Westlaw, Google, and World check to identify entities and derogatory information.• Drafting and submitting 314B Request for Information (RFI) to the correspondent banks if deemed necessary.• Performing a pull-down from GIFTS, and formatting the extracted spreadsheet, with separate tabs and grouping the Counter-parties and sub-total percentage for better assessing the case.• Based on familiarity with the Patriot Act, BSA, OFAC and 314A\B laws conducting Manager Review for cases forwarded to us by the Case review and case creators team for further action. • Compiled data and prepared management report for SAR filings and OFAC hits.

Anti Money Laundering (AML) responsibilities mandated by the USA PATRIOT Act and the US Department of Treasury, consist of analyzing transactions, escalating suspicious transactions and ultimately submitting a Suspicious Activity Report (SAR\STR) to the U.S. Treasury.Lead technologist to assist the Director of AML Surveillance unit on any Technology issues that may arise.Monitor accounts to ensure compliance with BSA regulations and Anti-Money Laundering (AML) legislation.Perform investigations of and enhanced due diligence for accounts/customers that pose the highest financial and reputation risk to the bank.Compile data and prepare appropriate reports to support investigative findings.Present investigative findings of suspicious activity to the IDBNY SAR Committee.Utilized investigative reports and the Bank's customer KYC files to prepare SARs using Mantas, SWIFT and Prime web based applications to support the research conducted. Ensure that SAR reflects all relevant negative information.Provide compliance-related support specific to assigned function; ensure compliance with various regulatory requirements by tracking data for examinations as required by area supported.Used tools such as Westlaw, World Compliance, Jack Henry, FiServ, Designated Names, Deutsche Bank Imaging and internet search engines to fully research and completely analyze each case before final decision. HSBC - (Subcontracted under Deloitte & Touche FAS)AML

Supervised directly under private bank's risk manager & compliance vice president.Analyzed, researched and involvement in the remediation process of several SCC (Special Category Clients) and PEP cases with major real estate involvements in NY.Using Bank's AML\KYC system to update SCC entities' crucial information, and to comply with 'Wolfsberg Group' guidelines.Remediated and completed compliance tasks with Deloitte & Touche FAS team to complete the RSD database.Reviewed, remediated and compiled over fifty (50) revocable and irrevocable Trusts for the purpose of identifying Grantors, Trustees, and all Beneficiaries so that it can be approved by the Bank's AML division.Utilized Real Estate and investment background to fully remediate over 150 entities with investments in the NY real estate market.Utilized search engines such as Lexis Nexis, Westlaw, Google, CIF and bank's internal database: RCD and KNYCE for investigation tasks.

Investigation - SAR Drafter

Supervised a group of 20 staff members to meet their quarterly quotas.Trained them on weekly basis to prepare financial applications, board packages and how to read tax forms and general ledgers from KYC perspective.Validating Customer funds, investments, net worth, net operating values and debt. Generated over $12M in sales in the first two (2) years, which resulted in a quick promotion.