Legal and Regulatory Consultant

ALBERT M. SALOMON, ESQ., CAMS

******.*.*******@*****.***

Tel: 646-***-****

Compliance Consulting – Risk Management – Legal and Regulatory Advisory Albert M. Salomon is a Certified Anti-Money Laundering Specialist with a proven ability to manage complex AML risk for diverse financial institutions ranging from global online payment services to multinational banks. Successfully collaborated with front-, middle-, and back-office personnel to implement all aspects of AML compliance policies and procedures. Previous engagements include event-driven reviews, client onboarding, transaction monitoring, and remediation projects. Highly effective in:

• Audit Advisory

• Complex Client Onboarding

• Commercial Database

Research

• Drafting Policies and

Procedures

• Legal and Regulatory

Document Review

• Legal Writing / Research

• OFAC Screening

• PEP Screening

• Quality Assurance (QA)

Review

• SAR Drafting

• Transaction Monitoring and

Analysis

HIGHLIGHTED CAREER

ACHIEVEMENTS

• Participated in 9-week Mandarin language course while working on-site as OFAC Advisor for U.S. subsidiary of major Chinese bank. Attained rudimentary knowledge of Mandarin and can identify simple Chinese characters. (Pinnacle Connections, LLC)

• Drafted provisions of Quality Assurance manual used to assess compliance with AML policies relevant to various banking products and services. Manual was implemented across several Lines of Business for major international Corporate and Investment Bank. (Promontory Financial Group)

• On-boarded multi-tiered State-Owned Enterprises along with numerous publicly traded corporations. Collaborated with several business units to complete the above while maintaining optimal client experience. (Morgan Stanley)

• Coordinated ad hoc OFAC remediation assignment involving payments encompassing three years of banking activity. Flagged, investigated, and successfully addressed over 400 payment alerts within one business week. (Morgan Stanley)

• Reviewed transaction-monitoring alerts involving ultra high-risk foreign correspondent banking accounts. The accounts’ source of funds, high dollar amounts, and relation to high-risk jurisdictions necessitated an unparalleled degree of scrutiny for successful review. (Habib Bank Limited) EMPLOYMENT SUMMARY

Pinnacle Connections, LLC – OFAC Advisor June 2018 – August 2019 (Contract) GRC Solutions – AML Investigator / QA Analyst February 2017 – February 2018 (Contract) Promontory Financial Group – AML Audit Advisor November – December 2016 (Contract) IPSA International – OFAC Sanctions Analyst March – August 2016 (Contract) Habib Bank Limited – AML Investigator January – February 2016 (Contract) Morgan Stanley – AML Investigator May – December 2015 (Contract) Navigant Consulting, Inc. – AML Analyst October 2014 – April 2015 (Contract) PROFESSIONAL EXPERIENCE

Pinnacle Connections, LLC June 2018 – August 2019 (Contract) OFAC Advisor

Performed high-level OFAC-related assignments for U.S. subsidiary of major Chinese bank. Ø Evaluated sanctions exposure presented by bank customers after applying risk ratings developed during bank’s Risk Assessment. Drafted preparatory memoranda for review by Chief Compliance Officer and recommended entering or exiting customer relationships based upon several factors, including bank’s overall risk appetite. Collaborated with senior management to strengthen the control environment surrounding the banking activities of numerous high-risk customers.

Ø Performed gap analyses in response to Internal Audit findings. Identified inconsistent policies and procedures, conflicting reporting lines, and unclear roles and responsibilities involving periodic review of bank’s customer population.

Ø Researched legislation and regulations affecting bank’s Corporate Compliance Department. Drafted new policies and procedures to reflect updated legislative and regulatory requirements. Ø Collaborated with bank’s Information Technology, Treasury, Legal, and Operations departments to draft several desktop manuals and other procedural documents, including procedures related to verifying and storing OFAC licenses, and managing bank’s blocked and rejected payment accounts.

Ø Gathered and reviewed documentation to prepare for NYDFS Part 504-mandated annual certification. Ensured that bank’s Risk Assessment contributed to a sanctions filtering program that was reasonably designed to interdict transactions prohibited by OFAC. Ø Tested tuning thresholds for new rules introduced into bank’s transaction monitoring system. Ø Drafted memorandum on FinCEN’s Advisory on the Iranian Regime’s Illicit and Malign Activities and Attempts to Exploit the Financial System. Analyzed efficiency of Bank’s trade finance sanctions screening program in light of Iran’s use of shell companies to procure sanctioned goods and technologies; Iranian use of procurement networks to obtain dual-use equipment for ballistic missile proliferation; use of circuitous shipping routes to evade sanctions related to the commercial aviation industry; and other deceptive shipping practices used to evade U.S. sanctions.

Ø Executed test scripts for pre- and post-implementation testing of OFAC screening software. Reviewed screenings of Fedwire and SWIFT messages to ensure that Specially Designated Nationals (SDN) and other sanctioned entities were properly identified. Reviewed transactional message data for altered payment instructions, wire stripping, and other forms of data manipulation.

GRC Solutions February 2017 – February 2018 (Contract) AML Investigator

Investigated potential money laundering and terrorist financing occurring in regional consumer bank as part of comprehensive remediation project.

Ø Monitored unusual transactions detected in personal checking and savings accounts, certificates of deposit, business accounts, and lines of credit. Ø Prepared and drafted comprehensive reports tracing flow of funds through the financial system. Ø Investigated religious charities, educational institutions, and local small businesses to detect potential fraud, money laundering, and other abuses of the financial system. Ø Utilized banking software to retrieve Currency Transaction Reports (CTR), Suspicious Activity Reports (SAR), and other records and files relevant to a financial investigation. Quality Assurance Analyst

Ensured that work product generated by investigative team adhered to accepted policies and standards. Ø Assessed reports produced by AML investigators. Graded reports based on accuracy of findings, quality of analysis, clarity, and adherence to guidelines set forth in compliance manuals. Ø Improved overall quality of work product by identifying and correcting recurring errors and omissions. Reviewed finished product with investigators to ensure quality of future output. Ø Trained new investigators and monitored performance throughout duration of project. Promontory Financial Group November – December 2016 (Contract) AML Audit Advisor

Conducted holistic audit of AML Sanctions Compliance Program for major international Corporate and Investment Bank.

Ø Improved overall performance of AML Sanctions Compliance Program by identifying and correcting deficiencies in Bank’s existing Core Compliance operations. Ø Tested and reported on efficiency of automated interdiction software used for screening OFAC lists, internal whitelists, and USA PATRIOT Act Section 314(a) and (b) requests. Ø Drafted provisions of Quality Assurance manual used to assess compliance with AML procedures relevant to several product offerings, including international wire transfers and Trade Finance activity.

Ø Reviewed Trade Finance agreements, Standby Letters of Credit, bills of lading, cargo manifests, and other documents related to foreign trade contracts. Ø Prepared metrics and data report of Quality Assurance Process. Provided monthly overview of Sanctions Analyst performance to senior management. IPSA International March – August 2016 (Contract)

OFAC Sanctions Analyst

Performed secondary review of OFAC sanctions alerts for global Money Services Business (MSB). Ø Reviewed alerted transactions to ensure compliance with economic and trade sanctions against targeted foreign countries, known terrorists, narcotics traffickers, and other SDNs. Ø Screened clients against multiple government watch lists with a focus on entities located in the Middle East and Asia.

Ø Examined foreign passports and other documents to determine their legitimacy and to verify client identity.

Habib Bank Limited January – February 2016 (Contract) AML Investigator

Monitored Foreign Correspondent Banking (FCB) transactions involving clients located in High-Risk Jurisdictions.

Ø Drafted narratives explaining alerted wire activity following due diligence review of transacting parties.

Ø Communicated with foreign branch offices to assist in clearing OFAC alerts. Ø Identified suspicious activity and escalated cases for further review when appropriate. Ø Performed Quality Assurance review of work product generated by transaction monitoring team. Morgan Stanley May – December 2015 (Contract)

AML Investigator

Protected global financial services firm from reputational and financial risk by investigating potential money laundering, terrorist financing, political corruption, and other criminal activity. Ø Exercised Enhanced Due Diligence (EDD) to screen and onboard various business entities, private trusts, State-Owned Enterprises, charities, high-net-worth individuals, Politically Exposed Persons (PEP), and other high-risk banking clients. Ø Reviewed alerts generated by automated monitoring systems to identify adverse media on existing clients.

Ø Drafted and escalated SARs to bank management after detecting suspicious activity or other risk- relevant concerns.

Navigant Consulting, Inc. October 2014 – April 2015 (Contract) AML Analyst

Conducted due diligence research as part of AML remediation project for major retail bank. Ø Interfaced with senior analysts to prepare case files for SAR escalation process. Ø Compiled account information and monthly bank statements to gain a holistic understanding of customers’ transactional history and financial profile. BAR ADMISSION

State Bar of New York, December 2014

PROFESSIONAL

CERTIFICATIONS

Certified Anti-Money Laundering Specialist (CAMS)

EDUCATION

• St. John’s University School of Law, Queens, NY. Juris Doctor, 2013 Honors: Dean’s Award for Excellence in Criminal Law

• Brooklyn College, Brooklyn, NY. Bachelor of Arts, cum laude, Philosophy and Law, 2009 Minor: Business Law

INDUSTRY KNOWLEDGE

• Bank Secrecy Act (BSA)

• Basel Committee Core Principles

• CDD and EDD policies and procedures

• First, Second, & Third European Union

Directives on Money Laundering

• Financial Action Task Force (FATF) 40

Recommendations

• FinCEN Guidelines

• Foreign Account Tax Compliance Act

(FATCA)

• Foreign Corrupt Practices Act (FCPA)

• Know Your Customer (KYC) standards

• OFAC regulatory policies

• USA PATRIOT ACT

TECHNICAL SKILLS

• Westlaw certified

• LexisNexis certified

• Actimize

• Banker’s Toolbox

• Factiva

• FIS/Prime Compliance Suite

• FircoSoft

• Microsoft Office Suite

• Norkom

• Patriot Officer

• Regulatory DataCorp (RDC)

• SharePoint

• STAR

• World Check

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