Manager Project

Rajpal K. Ramrakhiani, CAMS

**** ******* ******, *** **** Park, NY 11040

Phone – Cell: 917-***-****, Home: 516-***-****,

Email: ******************@*****.***

Summary

Certified Anti-Money Laundering Specialist (CAMS).

18 years of banking experience in New York including 6 years of direct AML Compliance,

transactions monitoring and Investigation experience.

Worked as senior AML Investigator at 4 major Look back / Backlog projects including 3

conducted / managed by Daylight Forensic and Advisory LLC, Promontory Financial Group and

Dominion Advisory Group.

Good understanding, knowledge and experience of all operational departments and wide range of

banking products such as retail, commercial, trade finance, private banking and international

correspondent banking.

Strong knowledge of Bank Secrecy Act (BSA), Anti-money laundering (AML) procedures and

OFAC regulations.

Worked on the Bank’s Internal Risk Management Committee in preparation for making the bank

compliant with Basel II – capital adequacy standards.

Excellent AML Investigation and complex SAR preparation skills.

In depth working experience with various AML software packages including PRIME,

SEARCHSPACE and KPMG’s CASE MANAGER.

Proven technical, analytical and investigative skills.

Strong oral and written communication skills.

Ability to work both independently and in team environments.

PROFESSIONAL EXPERIENCE

Federal Reserve Bank of New York - (Consulting Assignment) 03/2009 to Present

Senior Analyst - AML Compliance Department, TALF (Term Asset Backed Securities Loan

Facility) Project.

Responsibilities at the FRBNY are of confidential nature but broadly speaking, include the following;

• Conduct enhanced due diligence research on potential TALF borrowers, related entities and

individuals.

• Conduct background screening / negative news checks and adverse information checks from

Anti-Money Laundering point of view, on potential TALF borrowers, related entities and

individuals using proprietary databases such as Lexis Nexis, World Check as well as various

public Internet search tools such as State records, SEC and Federal records etc.

• Verify compliance with all relevant eligibility criteria for the borrowers and the collateral offered

for the TALF loans.

• Review Anti-Money Laundering policies of other financial institutions which send the proposals

for TALF loans.

• Provide preliminary recommendations on the acceptability of potential TALF borrowers.

Dominion Advisory Group / RSM McGladrey 07/2008 to 11/2008

(Consulting Assignment through AML ANALYTICS, INC)

Senior AML Investigator and Quality Control Reviewer at Washington Mutual’s Look Back and

Back Log projects (WAMU has since been taken over by JPMorgan)

The project was for transactions monitoring and covered all divisions of WAMU including Retail

Banking, Consumer Finance and Small Business etc. Responsibilities included reviewing alerts,

deciding whether alerts were to be converted in to cases, conducting investigation on counter parties

using non-proprietary and proprietary databases such as Lexis-Nexis, World Check, Westlaw and other

internet search tools, identifying suspicious transactions / patterns and documenting red flags, preparing

SARs, reviewing SARs prepared by other investigators before filing with FINCEN and performing

quality control checks on the team’s work. The project was conducted at Albion, which is located near

Rochester, NY.

Promontory Financial Group (Consulting Assignment through AML ANALYTICS, INC)

12/2007 to 07/2008

Senior AML Investigator at the American Express Look Back / Back Log projects

The projects were mainly for transactions monitoring of International wire transfers. Responsibilities

included:

• Review cases to confirm whether or not the thresholds are met and alerted red flags are present

in the transactions.

• Identify and document additional red flags and suspicious patterns.

• Conduct and document research on individuals and entities using proprietary databases as well as

various Internet search tools.

• Write case Notes summarizing the reasons for case creation, transactional activity observed, red

flags and suspicious patterns found, result of the research conducted and determination /

conclusion whether or not the transactions appear to be suspicious.

• Send RFIs (Requests for Information) to overseas offices of AMEX bank to obtain additional

information, if necessary, on the counterparties of suspicious transactions.

• Research the internal bank databases for prior RFIs and prior SARs.

• Put up cases to SAR Committee if the suspicious transactions remain unresolved in the event that

RFI responses are not received or are inadequate.

• Prepare SARs for submission to FinCen.

• Recommend Account closures and putting entitles on ‘Watch List’ or ‘Entity Blocked List’.

ISRAEL DISCOUNT BANK OF NEW YORK 4/2006 to 12/2007

Senior Compliance Specialist (AML Investigation)

The AML Compliance position of about 20 months at the Israel Discount Bank included 9 months

conducting the AML Look-back project at the offices of the bank’s consultants Daylight Forensic

and Advisory LLC.

January 1, 2007 to September 30, 2007: Worked on the Bank’s Lookback project under ‘Cease &

Desist’ order as Project Leader. Responsibilities included AML Compliance review of the cases

generated by the CMS, review of EDD on individuals / entities conducted by analysts, deciding whether

or not the transactions appearing in cases are suspicious, closing the cases or recommending appropriate

transactions / suspects to be reported in SARs. I guided a team of 11 analysts, investigators and SAR

Preparers throughout the project duration. I also conducted AML investigations in large and complicated

cases. The project which had more than 7,500 cases was successfully and timely completed with filing

of about 3,700 SARs with the help of bank’s consultants Daylight Forensic and Advisory LLC.

April 12, 2006 to December 31, 2006 and October 1, 2007 to December 10, 2007: Worked in the

bank’s AML Compliance monitoring unit where the responsibilities included the following.

• Ensure compliance with Bank Secrecy Act, USA Patriot Act, ‘Know Your Client’ Policy and

Customer Identification Program requirements.

• Ensure compliance with Bank’s internal Anti-Money Laundering policy.

• Responsible for risk-based enhanced due diligence (EDD); transaction monitoring of large

international wire transfers for thresholds, red flags and suspicious patterns.

• Worked on the Bank’s Internal Risk Management Committee in preparation for making the bank

compliant with Basel II – capital adequacy standards. This included assigning risk score to each

major customer of the bank as per the risk matrix finalized by the bank in consultation with

outside experts.

• Responsible for reviewing all the alerts created by Prime AML Application and researching

Prime cases for possible money laundering and terrorist financing patterns.

• Identify and summarize complex series of transactions indicative of layering activity involving

multiple accounts, financial institutions, entities, and jurisdictions.

• Identify and summarize unusual transaction activity involving cash structuring, use of circuitous

payment routes, potential U.S. based foreign shell entities, high risk parties based on adverse

information found, high risk geographic locations, businesses involved in high risk industries,

and transaction activity inconsistent with the expected purpose of the account.

• Review incoming and outgoing domestic & international wire transactions involving High Risk

and Terrorist associated countries.

• Participate in a Money Service Business research assignment to identify and report customer

accounts that are providing undisclosed MSB services.

• Conduct customer background searches utilizing Lexis Nexis records, Westlaw, World Check

references and related information found through internet search engines.

• Review customers' KYC profiles and Signature Card statements to cross-reference with alerted

account activity.

• Handle FINCEN requests for information sharing under section 314(a) of Patriot Act.

• Receive & respond to information sharing requests received from other financial institutions

under section 314 (b) of Patriot Act

• Assist in identifying and resolving audit issues.

• Work closely with Global Relationship Managers and interact with marketing division of the

bank for obtaining additional information/documentation on suspicious transactions / entities.

• Document all research findings in case files.

• Maintain and update AML related databases

• Prepare Suspicious Activity Reports (SARs) including additional and amendment to previously

filed SARs.

• Recommend entities to be put on watch list and exclusion list etc.

UNION BANK OF CALIFORNIA INTERNATIONAL-New York 9/1995 – 4/2006

Internal Risk Control Analyst, AML Investigation 6/2003 – 4/2006

• Review and analyze transactions for potential suspicious activity and possible violations of

BSA / AML and file timely suspicious activity reports with FinCEN.

• Exclusive monitoring of Correspondent banking accounts involving very large transactions.

• Perform Enhanced Due Diligence for accounts/customers that pose the highest financial and

reputation risk to the bank.

• Prepare Suspicious Activity Reports documenting possible international customer money

laundering and terrorist financing activities to ensure compliance with the Bank Secrecy Act, the

USA PATRIOT Act, OFAC Regulations, and Federal Bank Reserve applicable rules and

regulations.

• Work closely with Union Bank of California International Project Manager and Team manager

to meet project goals and objectives.

• Manage compliance with Section 314A of the USA Patriot Act of 2001.

• Review & release OFAC items having economic and trade sanctions based on US foreign policy

and national security goals

Business Systems Analyst 3/98-6/03

• Supporting various banking software applications and testing software systems used for global

funds transfers and enhanced due diligence, transaction monitoring, and AML international

profiling. Systems supported include AS 400, WINDOWS 2000/XP, Microsoft Office 2003,

Active Directory, Lotus Notes, SWIFT, MIDAS, GFT, Citrix, VPN, Rumba, Virtual Office etc.

Senior L//C Specialist 9/95-3/98

• Examining documents received under letters of credits, interacting with beneficiaries for

correction of discrepancies, obtaining additional documents under L/Cs, communicating with

L/C issuing banks overseas, creating deferred payments and loans against future payments,

communicating with reimbursing banks etc.

IMPORT CREATIONS, INC.-New York 1/94-8/95

Import Manager

Responsibilities included handling all the imports of garments and fabrics from various Asian countries,

managing the letters of credits and international collection bills and managing the company’s credit line

facilities with banks and factoring companies.

BANK OF INDIA-New York Branch 4/91-12/93

AVP (Credit)

Responsibilities included analysis of client financials, oversight and periodic reviews of commercial

loans, residential and commercial mortgages, loans and credit line facilities, letters of credit, trade

finance & international bills of collection.

BANK OF INDIA-New Delhi, India 12/73-3/91

Chief Manager

Positions included Chief Manager of the main branch in New Delhi, Deputy Chief Manager (Credit) of

Industrial Finance branch and Manager of Okhla Industrial Park branch. Responsibilities included retail

banking, corporate finance, trade finance, issuance of letters of credits, foreign exchange dealings,

institutional deposits and operational management of branches. I reached a senior management position

in the bank by 1991.

Education:

Certified Anti-Money Laundering Specialist (CAMS) –USA – 2005

Certificated Associate The Indian Institute of Bankers (C.A.I.I.B).

B.S. (Civil Engineering) – BVM Engineering College, India.

Residential Status: U.S. Citizen.

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