Senior Compliance Risk & Fraud Investigator – Senior Internal Auditor – Quality Assurance Expert
Internal Audits
Independent Reviews
Quality Assurance
Quality Management
Risk Assessment
OFAC Sanctions
BSA/AML/KYC
SAR Filing
Fraud Analysis & EDD
Compliance Testing
FinCEN Regulation
Systems Analysis/Implementation
Project Management
Regulatory Framework
Securities
FINRA
Paisley GRC
Participated in various highly complex international audit assignments involving fraud, key-stone reviews, and special investigations. Developed and implemented detailed project plans, including new Remote Deposit Capture (RDC) products at Standard Charter Bank, JP Morgan Chase and Citigroup. Managed planning, documenting, testing and execution to successfully complete projects on and within budget. Developed documentation to support the project planning and implementation process.
Strong and successful experience in building and executing Compliance Risk Management Programs (CRMP) to assist institutions in extinguishing compliance and management related enforcement actions imposed by regulatory authorities.
Developed, administered and supported organizational Risk Assessment Methodologies focusing primarily on Compliance and Operational risk. Program elements included key risk identification, documentation of risk handling activities, risk ratings at the inherent and residual levels, ensuring risk owner accountability and reporting and escalation processes.
Professional Experience
Global AML PMO Program Lead 07/2017 - Current
Citigroup, Irving, Texas
Drive implementation of Project Management (PM standards), procedures and templates for Anti-Money Laundering (AML) key initiatives, programs and projects.
Support QA process, identifying instances of non-compliance to standards followed by tracking and verification of correctiveactions.
Solid understanding of internal audit standards, policies, and local regulations to provide timely audit assurance.
Cooperate with Enterprise Projects QA team to support external reviews for AML initiatives, programs and projects.
Contributes to the development of audit processes improvements.
Work in validating Internal and Regulatory issues as well as Corrective Action Plans as necessary.
Drive communication and training on PM practices and tools in PM and Project Management Office (PMO) community.
Reviewed laws and regulations for business impact and completes risk assessments.
Lead and motivated cross-functional team members in strategy development and implementation of compliance solutions.
Provides coaching to team members in all phases of the audit process.
Utilized advanced leadership and collaborative skills in interacting with compliance stakeholders or regulatory agencies.
Fostered cooperation across team and organizational units.
Built consensus and morale through understanding of underlying team dynamics and by promoting development of team relationships.
Accountable for achieving business objectives and results; provides guidance to cross-functional team members to ensure goal achievement and team success.
Drive to collect and share Lessons Learned between PMs and PMO community.
Partner with other AML and Citi business units such as Risk & Control, Process Re-engineering and Citi Program Management Transformation, as needed.
Support the Article Owner, Project Owners and Project Stakeholders with expertise in the preparation and consolidation of artifacts to demonstrate completed actions in response to the Office of the Comptroller of the Currency (OCC) and Federal Reserve Bank (Fed) Consent Orders, Matters Requiring Attention (MRAs) and Internal Audit (IA) issues.
Assist in developing and providing ongoing training to Citi AML and business employees regarding the production of quality documentation and effective communication with testers, auditors and reviewers.
AML/BSA Manager- (Transaction Monitoring) 12/2015 – 07/2017
Standard Charter Bank, Dallas, Texas
Manage three teams of investigators (alert monitoring as well as manual reports); review of SARs, requests to close relationships, communication with relationship managers, etc.
Serve as subject matter expert for various projects as well as lead working groups; implementation of various software systems and upgrades.
Developed ways to improve existing audit practices
Develop people managing skills for direct reports as well as investigators aspiring to become leaders
Responsible for drafting Suspicious Activity Reports (SARs) for submittal to FinCen.
Analyzee and review securities trading alerts for a large financial services firm with the objective to determine potential market manipulation, "pump & dump" schemes, insider trading and Section 5 violations.
Conducted internal investigations into attempted unregistered penny stock distributions, fraudulent wire requests, attempts to structure transactions, prime bank fraud and attempts to evade federal currency reporting requirements.
Pro-actively develop automated routines to help focus audit testing.
Solid understanding of how internal audit collectively integrates with line management and control functions to accomplish the objectives of the function and overall business.
Audited internal controls for accounts receivable, accounts payable, purchasing process, fixed assets, client accounts, vendor master files and customer master files.
Served on a Governance Team tasked to meet with an international bank's senior executives and scribe detailed memorandums and reports regarding the institution's AML Program including its corporate structure, workflows, reporting lines, policies and procedures.
Performed document reviews of corporate documentation, emails and internal correspondence to investigate potential client relationships with Office of Foreign Assets and Control (OFAC) sanctioned countries.
Ensured assigned testing responsibilities are performed within quality expectations, including appropriately supporting workflow documentation and reports.
Conducted reviews and investigations of Foreign Correspondent Banking (FCB) accounts.
Reviewed wire transfers to ensure compliance with OFAC and AML and provided final disposition on alerted cases.
Audit experience with proven abilities in taking responsibility for communicating and issuing to stakeholders high quality deliverables according to strict timetables.
Demonstrated awareness of personal leadership style and works to achieve quality results by motivating and inspiring highly skilled team of compliance professionals. Builds processes and relationships that facilitate productive teamwork.
Researched information on the main entity and the counterparties involved in transactions, maintaining a working knowledge of the Comprehensive Capital Analysis and Review (CCAR).
Utilized financial crime and compliance software and databases such as Norkom, Scion and Regulatory DataCorp (RDC).
Ensured compliance with the USA PATRIOT Act and the privacy regulations promulgated under the Gramm Leach Bliley Act (GLBA).
Sr. AML/BSA Compliance Team Lead 09/2015 - 12/2015
RABOBANK, Rosville, California
Responsible for monitoring, investigating and reporting suspicious activity on high risk domestic and international customers/businesses and foreign individual clients utilizing government sanctions and industry governed compliance laws and regulations.
Subject matter expertise regarding solid business understanding of Consumer Banking Retail products (including mortgages).
Developed effective line management relationships to ensure strong understanding of the business.
Serves as the primary resource for cross-functional team members on escalated issues of a unique nature.
Serves as the technical expert, providing direction to others on complex issues, and mentoring team members.
Managed all compliance issues of the Mortgage-Backed Securities Litigation department.
Created compliance related policies and procedural write-ups to implement risk management.
Led and supported compliance testing processes and activities, including reviews of controls related to data integrity in accordance with global compliance standards.
Analyzed and reviewed securities trading alerts for a large financial services firm with the objective to determine potential market manipulation, "pump & dump" schemes, insider trading and Section 5 violations.
Conducted initial investigation into any suspicious activity and created incident reports based on findings.
Managed investigations activities of group, responsible for fraud detection related activities in support of Customer Identification Program (CIP), Bank Secrecy Act (BSA) and/or AML regulations designed to prevent financial-related crimes against the government according to internal policies, procedures and legal/regulatory guidelines.
Leaded smaller scale audits and projects.
Reviewed over 300 documents a day for issues related to regulatory risk, reputational risk, operational risk, compliance, fraud, criminal and bank misconduct matters.
Served as Department's point of contact relating to compliance issues for the Suspicious Activity Response Team, Compliance, Legal Affairs and Corporate Administration.
Performed in-depth investigations to obtain and verify data during reviews.
AML/BSA Compliance Team Lead 10/2014 - 09/2015
Standard Charter Bank, Manhattan, New York
Developed and executed various compliance tests, produced reports for gaps and recommended enhancements to reduce risk.
Designing and executing tests to verify control effectiveness
Solid understanding of internal audit standards, policies, and local regulations to provide timely audit assurance.
Facilitated reviews on Micro Cap Securities alerts flagged across Wealth Management, Private Bank and Investment Bank business lines. Reported potential violations with internal controls, industry rules/regulations, and market conduct related securities fraud.
Applied expert knowledge of the business, its products and processes.
Provided foreign correspondent banking transaction investigation and monitoring.
Led audit assignments, managed staff and created Audit Planning Document’s (APD) and final audit reports for senior management.
Reviewed and analyzed wires from high risk countries for suspicious or unusual activity utilizing AML/BSA/KYC/OFAC guidelines.
Effective negotiation skills, a proactive and 'no surprises' approach in communicating issues and strength in sustaining independent views.
Maintained expert knowledge of the competitive/regulatory landscape and the company's key challenges.
Worked with Compliance department on margin letters, penny stock letters and the opening of new accounts to satisfy Oppenheimer's AML/KYC requirements.
Performed detailed Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) reviews.
Assessed activities/transactions for unusual or potentially suspicious activity to resolve cases.
Reviewed focus on prevention and detection initiatives, customer authentication and AML KYC based alerts for CIP exceptions as well as watch list filter review of hits for OFAC, Politically Exposed Persons (PEPs), and other screening efforts.
Utilized supporting documentation derived from investigative due diligence research to document findings in narrative style format in the case management system (managed through both manual and automated processes) and prepared reports to management as required.
Conducted investigations on suspicious activity arising from account surveillance, branch escalations and grand jury subpoenas.
Advised branch management and supervisory personnel on higher risk clients.
Escalated critical and reputational risk matters to the Financial Investigations Unit (FIU) Manager.
BSA/AML Compliance Consultant 10/2013 - 10/2014
JP Morgan Chase, Manhattan New York
Led audit assignments, managed staff, and created APDs and final audit reports for senior management.
Performed EDD reviews and risk analysis for current and newly acquired consumer/business accounts, cash intensive businesses accounts, charities foundation accounts, NRAs and wealth management accounts.
Responsible for audit engagements from risk assessment, pre-planning and reporting phase.
Prepared objective narratives detailing events, summarizing activities, referencing facts to determine if activity was normal or unusual.
Created and implemented various supervisory templates, which evidenced appropriate legal documentation, due diligence and supervision for penny stock deposits.
Facilitated reviews of domestic and international clients for possible violations of all relevant sections of the BSAct and USA PATRIOT Act, OFAC and SEC/FINRA regulations.
Analyzed account activity indicative of money laundering, terrorist financing, suspicious securities and fund movement patterns.
Ensured proper implementation of business requirements and identified outstanding compliance issues.
Advised branch management and regional supervisory personnel concerning risk and controls, in addition to implementation of the firm's policies and procedures.
Preformed AML risk assessments; utilized expertise policy and procedure writing and quality management
Prepared SARs.
Developed action plans for advancing compliance initiatives and for resolving outstanding compliance issues.
Analyzed initial correspondent banking transaction alerts to determine if further investigation was required based on the analysis of activity.
Utilized in-house research tools as well as external research tools to conduct daily investigations activities.
Recognized as the leading subject matter expert for penny stock reviews, assisted in ad-hoc reviews of penny stocks that led to firm policy changes.
Acted as subject matter expert for newer consultants joining team. Trained newer consultants regarding protocols, processes and systems.
Contribute to the development of audit processes improvements.
Updated statistics, identified patterns/trends and contributed to management reports for appropriate escalation of significant issues and accomplishments.
Compliance Analyst 09/2012 - 10/2013
Citigroup, Irving, Texas
Managed daily AML monitoring and review processes; produced reports on status of reviews.
Ensure assigned bankruptcy loans are handled in accordance with company policies and procedures, Investor guidelines, state laws and Federal Bankruptcy code and regulating agencies.
Performed moderately complex audits related to Credit Markets activities, technology management; project/program management; or supplier management in accordance with corporate methodologies and professional standards, including drafting of audit reports, presenting issues to the business and discussing practical solutions.
Apply solid understanding of how line management and control functions accomplish the objectives of the function and overall business.
Performed quality control reviews of client compliance documents.
Anticipated how the organization must adapt to changes in the industry to sustain competitive advantage.
Collaborated with control partners regarding compliance testing.
Monitored bankruptcy timelines to ensure outside counsel is completing bankruptcy milestones timely and communicate with attorney firms when necessary to get work completed.
Audited internal controls for sales and marketing, pricing amd quotation, customer complaints and purchase-to-pay processes.
Reviewed AML alerts and conducted investigations by gathering information from external resources.
Drafted and coordinated regulatory responses; provided information and assistance to correspondent firms such as the SEC on regulatory issues.
Skilled in preparing and reviewing closing documents and processing loans.
Applied expertise in BSA compliance for internationally focused activities, including international wires, remittance business and Commercial Lending.
Partnered with additional AML and fraud resources to support AML and fraud investigations across multiple lines of business
Utilized deep knowledge of BSA and Sanctions laws and regulations, including strong expertise in leading industry practices in BSA programs.
Executed OFAC reviews.
Initiated Section 314 of the USA PATRIOT Act requests to other participating financial institutions while advancing investigations.
Evaluated and interpreted federal laws and regulations and assisted in improving business practices.
Compliance Consultant QA 08/2007 - 09/2012
Bank of America, Dallas, Texas
Responsible for developing, implementing and overseeing all aspects of the BSA Compliance Program.
Coordinated the findings on high-risk clients and reported to line management.
Provided recommendations on exiting account relationships with customers that were suspected of criminal activity and posed a risk to the firm.
Independently performs audits related to Consumer Banking, technology management; project/program management; or supplier management in accordance with corporate methodologies and professional standards, including drafting of and presenting issues to the business and discussing practical solutions.
Gained specialized expertise in BSA regulations and FinCen guidelines relative to BSA SAR, money laundering schemes and investigative techniques required to detect such schemes.
Drafted, reported and presented individual audit observations for senior management.
Provided EDD on BAU cases as well as look-back cases.
Provides compliance input on business action plans, projects or operational requests. Planned and assisted with development and revisions of risk-based audit work programs.
Ensured information provided to the regulatory agencies was responsive to data requests.
Ensured transaction monitoring was risk-based and adequately covered higher-risk products, customers and geographies identified in the firm’s BSA risk assessment.
Supervised assigned department staff, including the BSA Manager and other assigned direct reports.
Managed compliance efforts as they related to complex federal regulatory requirements.
Advised the board, audit committee, compliance officer, senior management and other bank personnel of emerging compliance issues and consults. Guided the firm in the establishment of controls to mitigate risks relevant to the BSA Program.
Advised senior management on issues and has authority to make project-related decisions.
Audited internal controls for accounts receivable, accounts payable, purchasing process, fixed assets, bank accounts, vendor master file and customer master file.
Assisted in drafting responses to inquiries from employees regarding BSA/AML compliance and related issues.
Trained new project employee staff as needed.
Developed, designs and delivers compliance strategies to senior leadership; negotiates solutions with leadership.
Facilitated investigations based on inquiries from regulators (SEC and FINRA) and internal monitoring systems relating to insider trading, market manipulation, suspected money laundering and fraudulent financial activities.
BSA/AML Compliance Analyst 07/2004 - 08/2007
Washington Mutual Bank, Saint Louis, MO
Provided EDD on BAU cases as well as look-back cases.
Developed and delivers all types of messages effectively.
Identified and evaluated potential risks in an effort to mitigate risk exposure to the firm.
Completed reports and documentation in regards to KYC, CDD and CIP requirements.
Reviewed and analyzed account activity associated with PEPs for money laundering and terrorist financing risks.
Recommends appropriate and pragmatic solutions to risk and control issues.
Completed assigned audits within budgeted timeframes, and budgeted costs.
Independently completes assigned audits within budgeted timeframes and budgeted costs which may include intermittent travel.
Reviewed surveillance output and conducted surveillance analysis of trading and market activity.
Developed understanding of client financial operations by actively researching operational manuals and procedures.
Coordinates and responds to regulatory requirements and requests, and ensures the execution of conduct examinations.
Applied knowledge of key regulations to influence audit scope.
Reviewed low priced securities activity including penny stock deposits for potential red flags.
Prepared objective narratives; clarifying the details of events. In addition, summarized activities; referencing facts and determined if the activity required flagging.
Monitors the risk environment and assesses the emerging risks through the Business Monitoring process.
Analyzed and identified indicators of potential money laundering or terrorist financing activity from information sources such as surveillance/monitoring alerts, open source media reports and internal referrals.
Applied expertise in BSA compliance, banking regulations, FHA and HUD guidelines for internationally focused activities, including international wires, remittance business and commercial lending.
Worked with business and compliance stakeholders to review and resolve exceptions.
Conducted reviews and analysis to support regulatory exams, inquiries and other special requests.
Credit Analyst 03/2003 - 07/2004
Washington Mutual Bank, Saint Louis, MO
Worked with global surveillance and technology stakeholders on new and enhanced surveillances – including defining requirements, conducting analysis/UAT testing, and defining/implementing related processes and procedures.
Monitors the risk environment and assesses the emerging risks through the Business Monitoring process.
Develops effective line management relationships to ensure strong understanding of the business.
Anticipated and identified future needs, opportunities and potential solutions, and leads cross-functional teams through the problem resolution process.
Directed analyses and root cause identification; developed and recommended compliance solutions impacting the enterprise.
Works in validating Internal and Regulatory issues as well as Corrective Action Plans as necessary.
Established aggressive goals for the organization and monitors to ensure achievement.
Utilized federal, multi-state and local mortgage compliance regulations to assist manager with loan servicing.
Supported work streams in order to consistently deliver results that met or exceed client expectations.
Performed cash flow analysis and identified trends.
Managed compliance-led projects and represented divisional compliance on firm-wide and cross regional projects and working groups.
Handled blocked securities positional and exception reports. Ensured accounts were in compliance with the firms’ set micro-cap security activities.
Monitored high risk securities trading accounts for AML and/or fraud violations.
Performed due diligence/risk/performance reporting and developed testing strategies for Investment Committee.
Recommends appropriate and pragmatic solutions to risk and control issues.
Identify inconsistencies in data or results and defines business issues. Challenges policies, procedures or practices and formulates recommendations as necessary.
Reviewed, analyzed, filed reports for law enforcement on suspicious activity with regards to manipulative trading involving insider trading, marking the close, painting the tape, pump and dump, wash trading and penny stock fraud.
Education
Master in Business Administration (MBA) May 2013
Master in Public Administration, Southern Illinois University May 2011
Bachelors of Science, Harris-Stowe State University May 2008
Certifications:
Certified Fraud Examiner (CFE) August, 2017
ACAMS
Technical Skills
MS Office Suite expert (Excel, Access, PowerPoint)
Domino
LexisNexis/Westlaw/OFAC
Mantas
Accuity/Actimize/Tabloue
MS Project & Visio
World-Check
Norkom
Factiva
Palantir
Axiom
SharePoint
Kroll