Susana Herrera Email and Phone Number

Responsible for developing, implementing, and managing CEX.IO's compliance program.Review individuals and corporate accounts to ensure Regulatory Compliance is being maintained and responsible for maintaining current with industry standards and development in the area of KYC, BSA, and OFAC and apply regulatory requirements and internal policies and procedures to a case investigation. Planning, implementing and overseeing risk-related programs.Creating and coordinating proper reporting channels for compliance issues.

. Chosen to stablish the Company Compliance Program, Policies and Procedures and Company Risk Assessment.. Developed the AML/BSA and OFAC Policies and Procedures for Global and agents/delegates. . Created the Company Risk Assessment based in services, products, customers and countries served by the Company. . Drafted the company Business Plan together with expenses, budget and operation expectation/projection plan.. Applied in twelve states (Banking Department) to obtain the Money Transmitter License through NMLS including New York and Pennsylvania.. Registered the Company as “MSB” through FinCEN.. Created the AML/BSA Compliance Training Program for employees and agents/delegates.. Monitoring transaction activities from agents to confirm there are no structuring using method of payments such as: money orders, cash, payroll checks and credit cards. Prepare and File Currency Transactions Report and Suspicious Activity Report.. Reviewed transactions involving countries or entities regulated by the Office of Foreign Assets Control (OFAC).

. Reviewed Correspondent Banking Relationship files and updated applying “the Wolsberg principles”. . Reviewed all type of alerts (314 (a), OFAC match, Card and Wires Frauds processed through Verafin System and assigned them to the Compliance Analyst for in-depth reviews.. Prepared weekly report for all alerts reviewed by the analyst, escalated alerts, closed alerts, number of SAR’s and CTR’s filed.. Reviewed High Risk Accounts transactions and performed detailed analysis to detect pattern, trends, anomalies, and schemes in transactions, and relationship across multiple business. . Completed Annual Enhanced Due Diligence for High Risk Customers (Domestic and International Clients).. Communicated effectively with various business units to obtain necessary information for investigations.. Actively participated in conferences and other educational opportunities in order to stay abreast of changes in regulatory requirements.

• Developed and implemented a compliance program for Nobel Financial Inc. • Developed and implemented an AML/BSA/OFAC Compliance Manual• Prepared and applied for money transmitter licenses as well, surety bond for 42 state. • Performed detail analyses by State for international money remittance operations.• Developed and implemented the overall company risk assessment based on services and products.• Developed and implemented an AML/BSA/OFAC training for employees.• Performed Enhanced Due Diligence on third parties • Performed Due Diligence on Agent’s, Payers/Banks and Third Parties

• Developed and implemented the BSA Compliance Program for Money Services Business and Non-MSB (regular accounts)• Developed and implemented an ongoing monitoring process for the Money Services Business• Analyzed and performed Enhanced Due Diligences (EDD) in all high risk accounts, in addition, reviewed an ongoing basis. • Reviewed and enhanced the Risk Assessment for MSB’s customers and non MSB customers• Updated the MSB files and non-MSB files (KYC, CIP, OFAC, USA Patriot Act and PEPs)• Reviewed and filed Suspicious Activity Reports• Reviewed and updated the high risk customers profiles• Performed a site visit for all high risk customers and performed a presentation with the Compliance Committee meeting, in addition, the prospective closures accounts. • Monitoring in a monthly basis all MSB’s account and high risk accounts with a 10% of the expected activity provided by customers.