Assess anti-money laundering ("AML") programs for a variety of financial institutions (including banks, broker-dealers, money services businesses, and casinos) for compliance with the Bank Secrecy Act and federal AML regulations.

Successfully led complex investigations involving a wide range of sales practice, trading, and supervision violations. Recent cases concern securities fraud, Ponzi schemes, unregistered distributions, conversion, AML and BSA (Bank Secrecy Act) violations, excessive trading/churning, private securities transactions (selling away), and violations of FINRA’s advertising and corporate financing rules.• Led onsite examinations of financial institutions and drafted written requests for relevant documents and information.• Conducted thorough background research on pertinent individuals, companies, and financial products, using a variety of public and non-public databases and the Internet.• Performed comprehensive analysis of relevant facts and information, including financial data and statements, witness testimony and written statements, and financial institution and transfer agent records. • Conducted depositions and interviews of customers, potential respondents, and other witnesses.• Prepared high-quality investigative memoranda and visual presentations of findings.• Researched legal precedent and sanctions. Drafted legal analysis and recommended appropriate resolutions, including applicable sanctions.• Assisted in hearing preparation, including pre-hearing submissions, visual presentation of fact analysis, discovery, and witness preparation. Testified as lead investigator and fact expert in FINRA hearings.• Provided training and guidance to junior level staff.

Managing a team of five investigators, oversaw investigations involving market manipulation, unregistered distributions, improper sales practices, and NASD (now FINRA) advertising and corporate financing rules.

• Developed cases that successfully resulted in Enforcement actions against Nasdaq’s largest market makers for intentional late reporting of trades and backing away from their published quotations. • Designated by NASD to work with the Securities and Exchange Commission’s (SEC) Division of Enforcement to provide trading and market making expertise in the development of their cases against Nasdaq market makers.• Investigated illegal “IPO spinning” (profit sharing in aftermarket sales of IPO shares of hot public offerings in exchange for allocating IPO shares to select customers) by prominent investment banking firms. As a result, NASD settled disciplinary actions against those firms and a number of their employees.

Developed successful cases against “boiler room” firms for manipulating penny stocks, conducting unregistered distributions, and engaging in a variety of trading and sales practice violations.

Evaluated applications by NASD member firms to initiate quotations of securities (primarily penny stocks) on the OTC Bulletin Board and Pink Sheets for compliance with NASD Rule 15c2-11.