QUALIFICATIONS:

My goal is to bring a “Culture of Compliance” to every institution that I work with. I have testified in Federal Court, represented my agencies to outside agencies, and provided evidence to file charges of financial fraud by the respective law enforcement agencies in both State and Federal jurisdictions. I have internal audit experience with global financial institutions, investigative experience in strategic planning, implementation, and analysis of financial documentation for regulated entities, quality control management, and regulatory compliance experience with the Truth-in-Lending Act, the Home Ownership and Equity Protection Act, the Real Estate Settlement Procedures Act, the Fair Credit Reporting Act, and the Unfair, Deceptive or Abusive Acts or Practices Act; additionally, compliance specialization in the Bank Secrecy Act, and in Anti-Money Laundering Regulations such as, the USA Patriot Act. Furthermore, I have specialization in the Foreign Account Tax Compliance Act in order to assist with tax transparency. In addition, I can read, write, and speak Spanish, and would be consider fluent as a native speaker of Spanish.

WORK EXPERIENCE:

Raphael Impellizzeri aka The Compliance Solution Specialist October 2013 through Present

Independent Consultant – Florida, California, and New York (Project Consultant)

I handle regulatory and BSA/AML compliance for Financial Institutions, Money Service Businesses, Loan and Finance Companies, Casinos, and Investment Firms. I specialize in institutions that have regulatory or BSA/AML compliance issues that wish to address them in the most efficient and effective way possible.

My major duties have included:

Providing guidance to financial institutions with respect to the Bank Secrecy Act (BSA), the USA Patriot Act, the Truth-in-Lending Act (TILA), the Home Ownership and Equity Protection Act (HOEPA), the Real Estate Settlement Procedures Act (RESPA), and the Foreign Account Tax Compliance Act (FATCA) as well as many other State and Federal regulations.

Training staff with regards to properly implementing the Consumer Protection and Anti-Money Laundering (AML) regulations.

Conducting complex investigations in regards to AML issues, recommending the filing of suspicious activity reports when applicable, analyzing financial statements and other related documentation, gathering all available information on clients, and performing research and analysis of high-risk accounts with enhanced due diligence review requirements in regards to BSA compliance and tax transparency.

Conducting or participating in reviews, evaluations or special projects, and providing advice or technical assistance to management on developing program guidelines, risk ratings and enhancements to the AML monitoring systems in order to detect and report unusual or suspicious activities.

Updated and edited AML Programs including, building-out Policies and Procedures to more closely match the institutions process flows and operational structure.

Assisting in initiatives for the development, implementation and administration of BSA/AML compliance program, and participate in the development of training methodologies for conducting and documenting suspicious activities.

Routinely preparing project summaries, reports, memoranda, program guidance, or other documents related to the area of consultation along with serving on regulatory committees.

Conducting internal audits and system validations for institutions in regards to Regulatory and BSA/AML Compliance.

Development of processes for implementing Artificial Intelligence (AI) software and Machine Learning Systems into AML Monitoring Solutions.

Recalibration of parameters within AML Monitoring Solutions and operational decommissioning of the Monitoring Solutions to implement new software platforms.

During my time as an independent consultant, my major successes resulted in providing advisory and operation assistance to various types of financial institutions, such as: a consumer finance company, a global banking operation, an investment and private banking institution, a casino, and a community bank.

Financial Crimes Enforcement Network October 2012 through September 2013

Compliance Specialist – District of Columbia and Virginia (Term Appointment)

I handled regulatory compliance with BSA/AML regulations for Money Service Businesses, Securities Brokers and Dealers, Depository Financial Institutions, Precious Metals, Stones, and Jewelry Businesses, Casinos and Card Clubs, Mutual Funds, Credit Card Systems, Futures Commission Merchants, Loan and Finance Companies, and Insurance Companies. I was part of the Office of Compliance and Enforcement during my time as a Compliance Specialist.

My major duties included:

Performing research and analysis of highly complex issues associated with actions taken within FinCEN’s jurisdiction to identify problems, or deviations from regulatory requirements, preparing reports, or developing summary information or guidance for use by others.

Reviewing examiner information contained within applicable databases or reports of examination, and interviewing appropriate officials within and outside of FinCEN.

Conducting or participating in reviews, evaluations, or special projects, and providing advice or technical assistance to representatives of regulated industries, institutions, and federal and state regulatory partners on complex regulatory compliance issues, BSA requirements, FinCEN regulations and policies, or Treasury policies.

Assisting in initiatives for the development, implementation and administration of FinCEN’s compliance administration function to carry out the purpose of the record keeping, reporting and anti-money laundering provisions of the BSA, and participate in the development of training or educational materials.

Collaborated with other specialists in developing summaries of research and analysis of broad issues, and coordinating work with various FinCEN officials or specialist to assure communication and integration of efforts.

Guiding, assisting and helpings to train and orient analysts in the methodologies for conducting and documenting fact-finding and analysis activities, in addition to participating in program support to the IRS regarding delegated BSA responsibilities.

Routinely preparing project summaries, reports, memoranda, program guidance, or other documents related to the area of assignment.

Utilizing FinCEN Query, the centralized depository of all CTRs, SARs, FBARs, CMIRs, RMSBs, and DOEPs, I have conducted AML investigations by reviewing, analyzing, and documenting additional BSA violations than those initial noted within the ROE provided by the delegated Federal Regulator under an MOU.

During my time with FinCEN, my major successes resulted in me assisting in formulating examination and training processes, formulating spreadsheets and templates for FinCEN, and assisting senior management in developing process flows for compliance and enforcement actions.

Office of Financial Regulation April 2000 through October 2012

Financial Specialist – Florida (November 2007 through October 2012)

Financial Examiner/Analyst II – Florida (April 2000 through November 2007)

I handled regulatory compliance for Non-Depository Financial Institutions, Loan and Finance Companies, Money Service Businesses, and Securities Brokers and Dealers. I was part of the Division of Consumer Finance in the Enforcement Section during my time as a Financial Specialist and Financial Examiner/Analyst.

My major duties included:

Utilizing OFR’s examining procedures and methods in the performance and compilation of detailed examinations and complaint investigations of all financial entities in any area regulated by OFR.

Enforcing the Florida Statutes and Regulations of the Florida Mortgage Brokerage and Mortgage Lending Act, the Florida Consumer Finance Act, the Florida Retail Installment Sales Act, the Florida Title Loan Act, the Florida Commercial Collection Practices Act, the Florida Consumer Collection Practices Act, the Florida Control of Money Laundering in Money Services Business Act, the Florida Securities and Investor Protection Act, and enforcing the Interest and Usury practices of the State of Florida as determined by OFR’s case priorities or management assignments guidelines.

Routinely assigned as the examiner-in-charge, and assisting in the completion of difficult and complex examinations and complaint investigations.

Responsible for the timely preparation and submission of examination and complaint investigation reports, documentation, and work papers including timely completion of all proprietary databases-related activities, such as scanning, indexing, attaching case documentation, and creating and updating case notes.

Conducting or assisting in the on-the-job training of subordinate Financial Examiner/Analysts.

As part of the examination process, I reviewed Federal Laws and determined if violations had also occurred with respect to BSA/AML, OFAC, RESPA, HOEPA, TILA, FCRA, UDAP, UDAAP, and privacy regulations.

Gathered documentation through the examination and complaint investigation process that was later used as evidence in financial fraud investigations in which I participated in.

Generated reports for senior management to assess progress on compliant investigations and examinations.

Communicated Florida’s Financial Regulations to licensed and unlicensed entities and assisted those entities in complying with the appropriate regulation.

During my time with OFR, my major successes resulted in providing investigative support to federal, state, and local law enforcement agencies, training and empowered examiners in regulatory compliance, assisting investigators, detectives, and agents in understanding Florida’s Financial Regulations, and organizing small and large-scale public affair events. Over the years of service, I received multiple awards for outstanding service to the State of Florida due to my efficient manner in which I organized, prioritized, and timely completed work assignments, and by my initiative, drive, and determination to excel in every aspect of the understanding of the regulations in which I routinely governed.

Department of Agriculture and Consumer Services June 1994 through April 2000

Financial Examiner Analyst – Florida

I handled regulatory compliance for Agricultural Dealers in the State of Florida. I was part of the Bureau of License and Bond in the Field Examination Unit during my time as a Financial Examiner/Analyst.

My major duties included:

Conducting investigations of unlicensed entities, performing audits of agricultural dealers in determining the required fiduciary bond limit, assisting agricultural businesses with filing of administrative complaints, and auditing agricultural dealers to address improper compensation of agricultural products.

Routinely spoke at industry trade shows and meetings on the Florida License and Bond Law.

Communicated Florida’s Agricultural Laws to unlicensed entities and assisted those entities in complying with the regulations.

During my time with FDACS, my major successes resulted in being part of three consecutive Davis Productive Award winning teams for increasing production of agricultural dealer licenses year after year for three consecutive years. The Davis Productive Award is a prestigious award given by the State of Florida to agencies and personnel for efficiencies within the governmental operation that benefited the constituents of the State of Florida.

LICENSES AND CERTIFICATIONS:

Florida Slot Combo Professional Gaming License – Active (2016 to 2019)

EDUCATION:

Bachelor of Business Administration – Conferred in 1992 in the field of International Finance and Marketing from the University of Miami, located in Coral Gables, Florida.

SPECIALIZED TRAINING SEMINARS:

Completed the Anti-Money Laundering Workshop at Federal Financial Institutions Examination Council (FFIEC), and attended the Advanced Bank Secrecy Act / Anti-Money Laundering Specialists Conference in 2013 as part of my training as a Compliance Specialist with FinCEN.

Completed the following National White Collar Crime Center training courses as part of my training as a Financial Examiner with the Office of Financial Regulation:

Financial Investigations Practical Skills in 2001,

Financial Records Examination and Analysis in 2002, and

VIN Cloning and Motor Vehicle Title Fraud in 2011.

Completed the National Association of Consumer Credit Administrators (NACCA) Examiner Schools in 2000, 2005, and 2008 as part of my training as a Financial Examiner with the Office of Financial Regulation.

COMPUTER PROFICIENCY:

In Microsoft Windows and Office software with advanced knowledge in EXCEL, WORD, OUTLOOK, ACCESS, and POWERPOINT, Adobe Pro, LexisNexis, Dun & Bradstreet, GRS, CLEAR, Analyst Notebook, FinCEN Query, Jack Henry, ECS, GFX, 4sight, Synergy, Actimize, Patriot Officer, Metavante, Parc Plus, Liberty, DDS, TS2, TSYS, Image Center, World Check, World Compliance, Subserveo, NetX360, Globus, Global Relay, eBanking Pro, Logical Access, SDS, GCA, CMP, Bally’s software, Bravo, Everi/NuWave, and many other software applications that are more proprietary in nature; in addition, to knowledge of advance business analytic software such as, SAS, SQL, and other proprietary applications.

PROJECT EXPERIENCE SAMPLE:

OCC Regulated Community Bank – Florida December 2016 through May 2017

Senior Risk Specialist (Operational and Advisory)

In conjunction with Ascendo Resources, my initial function was to conduct special high profile EDDs of significant institutional clients for a De-Risking project; however, due to my expertise I was asked to train analyst and assist on additional projects that required me to do transaction monitoring, quality assurance reviews, and investigations.

Hialeah Park Racing & Casino – Florida June 2016 through February 2017

BSA/AML Specialist (Operational and Advisory)

As a direct hire consultant, my initial function is to address the BSA/AML Compliance Program and build-out the Policies and Procedures, including recommending the investigative applications and compliance software to be used by the Casino. After arriving onsite, I revamped the BSA reporting process from a manual function to an automated function for the Negotiable Instrument Log and the Multiple Transaction Log; implemented an investigative process for suspicious activity reporting; created a tracking process for investigations and filings to FinCEN; conducted investigations and made recommendations into courses of action including policy change; filed SARs and CTRs to FinCEN; and provided guidance on BSA/AML Regulations. I edited the AML training platforms in order to conducted training of Casino staff in regards to the BSA/AML regulations; made a member of the AML and SAR Committees in order to provide advisory services; updated and edited the AML Program; structured the methodology for EDD reviews and conducted them, and brought a “Culture of Compliance” to the Casino as the defacto BSA Officer.

EFG Capital International Corporation and EFG Bank – Florida April 2015 through January 2016

AML Compliance Associate (Operational and Advisory)

As a direct hire consultant, my initial function was to address the backlog of 8000 alerts of the investment firm and the private bank by determining if further investigation was needed into the activities of the high risk client base. After conducting the Level One Investigations I determine the proper course of action for the firm up to and including filing SARs. Additionally, I provided guidance on Policies and Procedures including rewriting procedures and edited the AML Program. I provided advice into inefficiencies that improved the investigative process, and the monitoring program that made it more effective after changing the parameters in one of the platforms and re-calibrated another monitoring platform. In addition, I assisted with the High Risk reviews involving tax transparency, proactive international wire monitoring reviews, an internal audit being conducted, and prepping for decommissioning of the multiple monitoring platforms.

FDIC Regulated Foreign Financial Institution Branches – New York March 2015 through April 2015

Compliance Officer (Internal Audit)

In conjunction with Slate Professional Group and Global Atlantic Partners, my initial function was to conduct the independent audit of the US branch of a Korean Financial Institution. My audit provided the information necessary to provide areas of concern for the BSA/AML audit that was forthcoming; additionally, assisted on a separate BSA/AML independent audit that was in process in order to bring it to completion with the appropriate areas of concern.

Global Financial Institution – California June 2014 through March 2015

AML Compliance Officer - Assistant Project Manager & Team Lead (Operational and Advisory)

In conjunction with Slate Professional Group and Global Atlantic Partners, my initial function was to investigate of negative news concerning the PEP client base of the depository institution; however, I was moved into SAR review section where I managed the data analytics to spot trends and correct issues by setting up training modules for FIU staff as the assistant project manager. I later managed the KYC Remediation project as team lead. My main function was to assign and QA work; however, because of my previous examination experience I did complex investigations and analysis to expedite work flow process. In addition, I managed the data reporting, created presentations for the Governance Board, and created specialized EXCEL worksheets for FIU staff and the CDD/EDD units to expedite the SAR and remediation projects, and acted as the BSA/AML regulations expert.

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