AML / KYC Advisory & Risk Management

Supervision and oversight of Mode Eleven (formerly Hulett Bancorp) and its subsidiaries (including Summit National Bank), ensuring compliance with all regulatory requirements and bank policies and procedures relating to KYC, CDD and EDD in the banking, payments (PSPs) and cards spaces. Managing a team of analysts responsible for the day-to-day execution of the KYC/CDD/EDD review process, with a focus on ensuring that customer due diligence information is appropriately synthesized, analyzed, documented and maintained. Developing new, and enhancing existing, risk-based policies and procedures. Liaising regularly with stakeholders across the bank, including business development teams, operations teams and executive leadership. Lead AML/BSA calls with clients’ compliance teams and executive management. Responsible for conducting on-site client visits with, or on behalf of, the BSA/AML and Sanctions Officer. Provide subject matter expertise with respect to new products/services, new client types and partnerships.
● Drafted and implemented the bank’s first KYC Policy, along with associated standards for CIP, Beneficial Ownership and Foreign Correspondent Banking. This included developing and implementing new processes around periodic client reviews, account restriction/closure protocols, conditional approval, risk overrides, etc.
● Developed and implemented monthly MI reporting detailing customer base composition, status of due diligence reviews, overall customer risk profile (including risk overrides), exceptions, escalations and other relevant information on customer and/or regulatory trends and patterns.
● Developed detailed DDQ’s based on customer type and product/service to be offered, including FCBs, PSPs and VASPs

Responsible for building a scalable Due Diligence and KYC Compliance Advisory Program (incl. EDD) to address the risks inherent in a growing, digital assets focused institution. Managed a team of five charged with executing the due diligence and KYC compliance programs across non-FFI/FCB and FFI/FCB clients. Developed new, and enhanced existing, risk-based policies and procedures, developed and delivered training to first and second lines of defense and created efficiencies in the workflow and feedback loop between first and second lines of defense – including advisory escalations, exception requests and QA driven remediations. Provided subject matter expertise with respect to remediation projects, new products/services, new market penetration, new client types, business expansion (e.g. B2B2B and B2B2C models), partnerships and engagement of third-party KYC service providers. Forged and maintained a productive, and constructive, partnership with Operations and Sales to ensure robust and compliant client onboarding and due diligence processes.
● Stood up a sustainable Quality Assurance program for effective oversight of first line KYC processes, the identification and management of client risk and the identification of systemic issues and training needs.
● Developed new, and revised existing, policies to better reflect regulatory requirements and expectations, resulting in a decreased burden on Operations personnel and an improved client experience.
● Lead BSA/AML Compliance engagement in the rollout of an automated KYC solution for the Bank, including the build out of the client risk rating tool and methodology.

Primary point of contact for Citi’s BCMA businesses, providing subject matter expertise on application of organizational AML policies, due diligence frameworks/controls and relevant risks and regulatory implications for new/modified products, services or initiatives. Primary point of escalation for matters related to KYC, AML, financial crime and due diligence. Oversight of internal quality assurance processes through participation in governance committees. Drove engagement with global partners and stakeholders, ensuring effective and comprehensive assessment and mitigation of potential AML risks.
● Led review of Global Spread Products businesses to identify and address AML/KYC gaps in financing and securitization activities not captured by the existing control framework.
● Ran point on identifying and ensuring remediation of 500+ clients and set up the scaffolding necessary to bring outlier business segments into line with Citi's broader AML control framework.
● Drove Citi’s AML policy responses to engagement with cannabis related businesses and Virtual Asset Service Providers.

Senior Compliance Officer, Anti-Money Laundering (2015 – 2017)
Managed the day-to-day work of the US AML team and functionalities of the US AML program and served as the SME to the business on AML matters. Led regular analysis of AML policies and program in order to realign processes with both internal and external changes/requirements as necessary. Crafted and rolled out the US AML Monitoring Program. AML Compliance oversight of new client relationships, firm transactions and third-party service providers. Conducted scheduled risk assessments to proactively identify and resolve potential vulnerabilities. Regular presentation of Management Information to Board of Directors.
● Successful management of the KYC/due diligence remediation of all US managed relationships, across all (four) investment managers.
● Successfully engaged, and transitioned the day-to-day KYC function to, the firm’s third-party due diligence service provider in the US.

Compliance Due Diligence Manager (2011 – 2015)
Helped to create, and led the implementation of, Man’s compliance due diligence function. Managed a small team of due diligence analysts charged with executing the program. Promoted collaboration between global stakeholders to develop and implement processes that supported efficient due diligence procedures while maintaining compliance standards across jurisdictions. Initiated and directed monitoring programs for AML, due diligence and KYC. Oversight of investigations related to matters of fraud, mis-selling, anti-bribery and corruption.
● Integral to the successful creation and implementation of the firm’s first compliance due diligence program, requiring review and remediation of 2k+ intermediaries, introducing brokers and private investors across four investment businesses.
● Successfully outsourced the KYC function to a third party service provider, allowing in-house due diligence team to function much more efficiently as a point of escalation.
● Developed review and approval process for non-standard initiatives relating to bespoke investment solutions/structured products and new market penetration.