ANDREA R. SHAW, ESQ.
Chicago, Illinois 60611 firstname.lastname@example.org
SUMMARY OF QUALIFICATIONS
Seasoned Legal and Compliance attorney with specialty in corporate compliance/governance, regulatory compliance and financial crime compliance. Strong knowledge and experience with interpreting and applying key U.S. and international regulations, including, but not limited to: SEC 1933 and1934 Act; Investment Company Act of 1940; Investment Advisors Act of 1940; FINRA Rules; Gramm-Leach-Bliley Act; Dodd-Frank; UDAAP; CFPB regulations; SOX; Bank Secrecy Act; FinCEN; O.F.A.C.; Reg. E/Y/H/K/W, U.S. PATRIOT Act (i.e., 312, 313, 314), Basel Accords (I/II/IIII), FCPA, and U.K. Bribery Act. Exemplary communication skills interfacing with and advising internal and external stakeholders. Resourceful, proactive, and proven leader known for responsible attitude, effective organizational task management, and strong research skills.
Conotoxia, Inc., Chicago, IL Chief Compliance and Ethics Officer & U.S. AMLRO, April 2018 Present
As the Chief Compliance and Ethics Officer & U.S. AMLRO for Conotoxia, Inc. (a licensed MSB with online platform), establish and continuously improve a consistent operating framework for the identification, management, monitoring and reporting of Compliance and Financial Crime risks and issues. Serve as regulatory liaison head and manage exams/audits when necessary. Develop an appropriate and effective training and communication strategy governing U.S. operations and for off-shore team in Poland. Design and implement regulatory change function to ensure Company complies with applicable statutory, regulatory and supervisory requirements. Monitor and investigate consumer complaints, instances of non-compliance and whistleblowing matters; determine corrective actions and report to regulators and Board of Directors as required. Participate in industry groups to ensure alignment of Compliance methodology and with national trends in Compliance Risk Management.
Within 90-days, designed and implemented enterprise-wide Compliance and Financial Crime framework to support launch of US operations. Tasks included, but not limited to: developing and implementing full suite of corporate compliance, consumer, vendor and financial crime compliance policies, procedures and controls governing U.S. operations (including for off-shore team in Poland).
Developed privacy (based on GLBA and GDPR) and related InfoSec frameworks for US operations.
Assisted with obtaining 10 state money transmitter licenses.
Deutsche Bank, New York, NY Vice President Anti-Financial Crimes, March 2016-April 2018
As the Americas Regional Head for the Global Anti-Financial Crimes (AFC) Central Unit team, implemented and oversaw the global-wide risk management and corporate governance framework as per German Banking Act 25(h) in the Americas region to ensure efficient decision-making and proper oversight over the financial crime risks faced by Deutsche Bank (DB). Supported the Global Financial Crime Governance Committee when necessary. Conducted risk assessment of financial crime risks type owners including AFC stake holders (Anti-Fraud, Bribery and Corruption, AML, and Sanctions), and non-AFC stakeholders (Legal, Corporate Services, and Chief Information Security Office) to identify and mitigate risk. Collaborated with each financial crime risk owner to develop corrective action plans and instill best practices. As the lead for the AFC Americas Governance team, oversaw and developed a sustainable corporate governance framework within U.S. 1LoD and 2LoD to ensure efficient decision-making and proper oversight over financial crime risks. Developed and reported financial crime challenges and required metrics to DB USA, DBTCA and DBNY Boards and sanctioned committees.
Oversaw the regional implementation of Global-wide AFC transformation project, governance and reporting deliverables by successfully working several senior business, infrastructure and control stakeholders.
Designed and implemented the remedial actions in relation to corporate governance findings stemming from the 2017 BSA/AML Cease and Desist and 2017 OCC Consent Orders
Conducted exam management when necessary. Managed two third-party monitorships pursuant to the 2015 AML/OFAC & Sanctions Cease and Desist order imposed by the FRBNY and by the N.Y.S. DFS. Coordinated with the team overseeing the U.K. FCA Skilled Person to ensure firm-wide response.
American Express, New York, NY Manager – Global Financial Crimes, December 2014-March 2016
As the Regional Head of ABC (Americas), managed and oversaw the daily operations of the team (3+ analysts) responsible for the United States, Canada, and Latin American Markets (LATAM) region. Provided advisory services to all business lines and markets across multiple geographical and regulatory environments to address and remediate potential corruption issues. Researched and analyzed legal developments in anti-corruption space; enhanced global-wide ABC policies and procedures as required. Oversee and administered enhanced due diligence on Vendors/Third Parties.
Developed Global ABC training and targeted trainings (Gifts/Entertainment, Charitable Donations, Hiring Practices) and administered to all levels of business and infrastructure divisions.
Successfully oversaw three key projects (project planning to execution phase): (1) Developing an ABC specific risk assessment and risk appetite statement; (2) automating monitoring of payments and gifts/entertainment to third parties; and (3) Developing stronger controls and processes for on-boarding intermediaries and business development consultants.
CLS Bank International, New York, NY Associate Compliance Counsel, April 2014–December 2014
Compliance Counsel primarily tasked with corporate governance and compliance. Assisted with the development of and implementation of the Compliance Risk Framework and Compliance Policy Framework for the CLS Group of Companies, including Edge Act Bank, and London, Tokyo and Hong Kong Offices. Developed, implemented and socialized a full suite of tailored global compliance policies and managed programs relating to each, including but not limited to: code of conduct/ethics, Whistleblowing, personal trading, conflicts of interest, privacy (GLBA), information barriers, advertising/marketing regulation, anti-bribery/corruption (FCPA/UK Anti-Bribery Act), gifts and entertainment, and AML/OFAC. Processed all required FRBNY and SEC corporate regulatory filings. Engaged with business lines to address compliance issues; and advise of compliance, regulatory, and legal risk. Reviewed marketing and promotional materials produced by the bank to determine regulatory compliance. Conducted internal investigations relating to Whistleblowing claims and internal policy/procedure violations and file SARs when necessary.
Developed and successfully deployed compliance training and targeted training modules for employees and board of directors. Targeted trainings included, but not limited to: suspicious activity training, information barrier, and cybersecurity.
Researched and prepared report for senior management examining the money laundering and corruption risk associated with on-boarding Russian and Turkish currencies.
Financial Industry Regulatory Authority (FINRA) Rockville, MD Senior Investigator, March 2013–April 2014
Senior Investigator in Corporate Financing Department. Conducted independent investigations of public and private placement offerings to determine potential fraudulent activity and violation of FINRA, SEC and other regulations. Reviewed and analyzed broker-dealers’ CRD filings, offering documents, and member-firm written-supervisory procedures, due diligence programs, anti-money laundering programs, and client documents to determine legality and compliance with securities rules/regulations. Prepared written reports and disposition letters resulting from investigations. Conducted legal research and provided formal interpretation and guidance of FINRA rules to member firms, other regulatory agencies, and the public. Collaborated with FINRA’s Enforcement division to develop corrective action plans for member firms and/or prosecute securities violations.
Successfully managed 30+ investigations with approximately 15% resulting in potential rule violations and referrals to FINRA’s enforcement division.
Conducted two major investigations that resulted in potential sanctions of over $3 million. The first investigation focused on suitability issues and excessive underwriting compensation received by a broker-dealer from the sale of two publicly offered Real Estate Investment Trusts. The second investigation focused fraudulent escrow account and violations of escrow procedures governing a private placement contingency offering.
UBS Financial Services, Weehawken, NJ Authorized Officer, Legal & Compliance, June 2011–March 2013
Conducted on-site audits of the UBS Wealth Management U.S. and Puerto Rico retail and private wealth branch offices to determine compliance with securities regulations and assess adequacy of internal controls. Identified red flags and deficiencies in processes, and presented corrective action plans to senior management. Advised Firm management of regulatory, reputational, and legal risk relating to exam findings. Provided interpretive guidance on firm-wide compliance procedures and rules and regulations to firm personnel. Prepared for audit by reviewing email and social media surveillance, cross border and anti-money laundering activity, outside business activities, suitability of client investments. Conducted preliminary research for trade corrections, annuities, mutual funds, syndicate offerings, commodities and other audit functions. Collaborated with firm’s legal department to escalate major violations.
Conducted 40+ on-site inspections. Lead examiner of team of up to 5 examiners on 20+ branch inspections. Managed and oversaw team members during pre-audit phase and during on-site exams. Served as a direct point of contact for regional officers and executive management.
Assisted with the on-boarding of newly hired examiners. Provided training of the exam program and guidance on conducting on-site inspections.
Morgan Stanley Smith Barney, New York, NY Attorney, Legal & Compliance, May 2009–June 2011
Attorney in Early Dispute Resolution group. Successfully managed a docket of 70+ cases. Investigated and responded to sales practice allegations that sought up to $200K+ in compensatory damages. Negotiated settlements with investors and opposing counsel when required. Interviewed complainants, registered representatives and senior management regarding sales practice allegations filed by investors. Conducted complex portfolio analysis to determine investor suitability and compliance with Know-Your Customer (KYC) rules/regulations. Conducted thorough investigation into various products including, but not limited to: equities, mutual funds, ETFs, structured products, annuities, commodities, and retirement service programs to determine compliance with rules/regulations. Responded to FRBNY, FINRA, SEC, NYSE, OCC, Commodities Futures Trading Commission, NFA, and state regulatory inquiries. Assisted with managing exams and monitorships sanctioned by the foregoing regulatory bodies.
Successfully defended in arbitration three cases in which the client sought over $1Million in compensatory damages involving claims of unauthorized trading, suitability, fraud and misrepresentation.
Assisted with the on-boarding of new dispute analysts and attorneys. Provided guidance and training on analyzing and assessing the viability of sales practice claims.
Albany Law School, Albany, NY Juris Doctor, May 2008
Specialization: International Law and Practice; Honors: National Order of Barristers
Hofstra University, Hempstead, NY Bachelor of Arts, Political Science, May 2003
Honors: Dean’s List: 8 Semesters; Full-Academic Scholarship
Licensed to practice in New York, October 2009;
Current Certifications: TRACE Anti-Bribery Specialist; and Certified Regulatory Compliance Manager (CRCM) (anticipated certification date December 2018).