ISDA / ILSA negotiator

THOMAS N. TRONOLONE

SUMMARY

Chief AML Officer for global investment firms, evaluating transaction monitoring processes and procedures from a both proactive and lookback perspective and preparing remediation plans to address any gaps. Prepared investigative files utilizing and drafted SARs as needed. Developed complete proprietary IT compliance test-script module to facilitate clear and accurate surveillance and analysis of counterparty risk. Governance point contact for senior management, department heads, and regulators during regulatory investigations and litigation. Positioned both Surveillance and Compliance teams as a resource for the business across all locations, tailored to individual business models, product lines and customer bases. Regulatory development analysis, drafting of policies and procedures, and staff continuing education training at all levels.

Independent Compliance Consultancy Service performing all ISDA / ILSA, 1940 Act Investment Advisory and broker / dealer independent testing, providing gap remediation and required annual reports. Draft policies and procedures in compliance with and anticipation of developing regulations, and provide continuing education to staff concerning both firm policies and SEC / FINRA rules. Generalist services for broker/dealer as well as all Investment Advisory functions. Full fixed income compliance services. Full Bank Secrecy Act compliance analysis, reporting and gap remediation. Drafting SARs in response to investigative findings in compliance with FinCEN guidelines and time frames.

TOWER LEGAL 05/2017 - PRESENT

ISDA / SWAPS DOCUMENT REVIEW / NEGOTIATOR

GOLDMAN SACHS

Review and remediate gaps in ISDA / ISLA documentation to ensure compliance with ISDA collateral requirements. Validate compliance with pending regulations and Goldman Sachs policies. Escalated potential remediations issues to senior management. Assisted in training other personnel. Provided legal analysis on potential conflicts of interest. Liaison with counterparties and Senior Sales to renegotiate terms for new and existing Master Agreements, CSA and post-execution amendments.

DELOITTE, JERSEY CITY, NJ 09/ 2016 – 02/ 2017

ISDA / SWAPS NEGOTIATOR

CITIGROUP

Prepared and negotiated ISDA agreements and contracts for Deloitte’s international counterparties to comply with March 2017 regulatory deadline. Liasion with Platinum counterparties to facilitate contract execution. Prepared training materials for junior staff and conducted training sessions. Ensured accuracy and mutual understanding of all contract terms and conditions. Monitored transactions to ensure quality control and regulatory compliance.

BANK OF AMERICA MERRILL LYNCH, NEW YORK, NY 12/2014 – 07/2015

COMPLIANCE OFFICER - VICE PRESIDENT

Prepared detailed documentation and reports for senior management regarding customer complaints. Resolved customer complaints and regulatory inquiries regarding high net worth clients and managed accounts. Review complaints in the context of all applicable regulations and firm policies. Partner with Office Management Team to provide effective resolutions. Escalate AML and compliance matters to director level to adapt firm policies to current matter trends. Performed transaction monitoring and drafted SARs. Provide coaching to sales force and managers in the context of complaint trends.

NATIONAL AUSTRALIAN BANK 12/ 2013 – 12/ 2014

AML ANALYST – COMPLIANCE ANNUAL TESTING

Evaluate, test and rewrite all AML / KYC compliance procedures and manuals including SARs process. Reviewed and identified gaps in all vendor and firm Contracts Book matters, preparing required annual remediation report. AML annual testing Project Manager for Commercial Bank’s Broker / Dealer division. Performed annual lookback of AML process, including SAR review and filings. Developed annual FINRA CEO Certification audit and testing program and complex litigation response. Coordinated SEC regulatory examination document production and response. Present findings report to Board and business line heads with gap remediation plan. Implement written remediation plan and training program.

TUXEDO COMPLIANCE VARIOUS 06/2008 – PRESENT

OWNER – PRESIDENT Provide compliance consultancy services to small broker / dealers on an outsourcing basis. Services include independent AML testing, along with gap identification and remediation plans and all attendant continuing education requirements. Provide required annual testing across all business lines for Annual CEO Certification. Ad hoc consultancy services for regulatory inquiries and litigation.

ROBOTTI & COMPANY ADVISORY, LLC, NEW YORK, NY 06/2009 – 05/ 2011

CHIEF COMPLIANCE OFFICER

Chief Compliance and AML Officer for an international Registered Investment Advisor and affiliated Broker / Dealer providing fee-based investment advisory services, institutional retail brokerage, and research. Managed full regulatory SEC audit of both business units, acting as sole regulatory liaison. Responsible for development and implementation of Board document and contract review initiative. Developed and implemented proactive transaction monitoring program. Performed marketing and advertising materials review, ensuring that all materials were reviewed and approved prior to dissemination to investors. Prepared supplemental AML memoranda incorporating results of testing. Prepared and administered required Continuing Education Plan and procedures review. Developed written procedures manuals and surveillance systems.

TUXEDO COMPLIANCE 01/2009 – 05/2009

OWNER / PRESIDENT

Independent AML testing, along with gap identification and remediation plans and all attendant continuing education requirements. Provide required annual testing across all business lines for Annual CEO Certification. Ad hoc consultancy services for regulatory inquiries and litigation.

SWISS RE CAPITAL MARKETS CORP, NEW YORK, NY 02/2003 – 12/2008

FOX-PITT, KELTON, INC. (FPK WAS SOLD IN 2007)

SENIOR COMPLIANCE OFFICER

Chief AML Officer for both Swiss Re and Fox-Pitt, Kelton, Inc. Coordinated independent annual AML testing program. Developed SAR escalation and lookback procedure for all business units and management. Prepared SAR memoranda as needed and on an ad hoc basis for regulatory examinations and investigations. Compliance generalist for both affiliated institutional firms engaged in fixed income alternative investments, proprietary trading, equity trading, and research. Responsible for daily trade monitoring and surveillance systems vendor selection, including contract negotiation. Develop policies, procedures and training in response to new regulations. Ensure that all policies and procedures are designed to achieve compliance with FINRA and SEC regulations.

LADENBURG CAPITAL MANAGEMENT - BETHPAGE, NY 1997 – 2002

COMPLIANCE OFFICER

Compliance generalist for Investment Advisory and international retail equity firms engaged in business with high net worth individuals and business owners, as well as proprietary trading, equity trading, and research. Responsible for testing, daily trade monitoring and surveillance systems development. Advise Board members and management on proper AML and supervision procedures. Develop policies, procedures and training in response to new regulations. Ensure that all policies and procedures are designed to achieve compliance with FINRA and SEC regulations.

EDUCATION: JD, New York Law School, New York

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