AML/BSA and OFAC Compliance: Practical Guidance for Banks and Financial Institutions

Mr. Crocker's practice focuses on regulatory and enforcement aspects of international business. Mr. Crocker has over 30 years' specialization in sanctions, export controls, foreign direct investment reviews by the Committee on Foreign Investment in the United States (CFIUS), anti-money laundering, Foreign Corrupt Practices Act (FCPA) and technology cooperation issues. He has particular expertise in the Office of Foreign Assets Control (OFAC) regulations, Export Administration Regulations (EARs) and the International Traffic in Arms Regulations (ITAR). 

Mr. Crocker has assisted some of the largest global financial institutions, as well as foreign and domestic companies in the technology, pharmaceuticals, biotechnology, chemicals, telecommunications and defense sectors, in policy counseling, regulatory interpretation, compliance, internal investigations and civil/criminal enforcement matters before the Departments of the Treasury, Commerce, State, Homeland Security, Defense and Justice. He also represents clients before Congress.

Jonathan is a manager in EY’s Financial Services Advisory practice. He joined the firm in 2012 after more than seven years with the US Government, including assignments within the Treasury Department, State Department and US Senate. In his current role, Jonathan advises global financial institutions on sanctions and money laundering risks, as well as the effectiveness of their compliance programs and system processes. While at the US Treasury, he was a senior policy advisor in the Office of Terrorism and Financial Intelligence, where he played a key role in developing and implementing strategies relating to economic sanctions and advising senior leadership on matters of national security policy. 

Jonathan speaks frequently before global industry groups on matters concerning financial sanctions. He recently co-authored an article entitled, Understanding sanctions: How to identify risk factors. 

Carol Spawn Desmond is counsel to Satterlee Stephens Burke & Burke LLP.  Her practice consists of financings and other commercial transactions; regulatory guidance to issuers, banks, investment advisers and NRSROs; and intellectual property and data protection advice to international clients. She is a frequent panelist for the Business Division of the New York State Bar Association (Securities Regulation Committee) and speaks widely on regulatory issues to financial services groups and other practitioners. Ms. Desmond is admitted to practice in the State of New York and in the United States District Court for the Southern and Eastern Districts of New York. Ms. Desmond earned her J.D. from Georgetown University Law Center, where she served as the Topics Editor of the Immigration Law Journal. Ms. Desmond earned a B.A., magna cum laude, from the University of Miami, Coral Gables, Florida.

• Donna DeMartino is a Senior Director with Alvarez & Marsal's Dispute Analysis & Forensic Services in New York where she is currently the lead in the BSA/AML and Compliance Technology Service Line. She brings more than 20 years of management consulting experience in leading and managing large, complex technology implementation efforts, investigations, BSA/AML Look Backs and Forwards and has supported compliance, forensic, dispute and quarterly audit projects with a specific focus on fraud detection.
• Ms. DeMartino has spent the last 13 years focusing on regulatory and compliance engagements within the financial services industry, specifically banking and brokerage. While she specializes in compliance related technologies, such as interdiction (OFAC), transaction monitoring applications, case and SAR management systems, she also has in-depth expertise in the policies and procedures that are captured in the business rules within the compliance's technology infrastructure (i.e., dynamic risk scoring, customer and enhanced due diligence, wire transfer transactions, e-payments, etc.).
• From a project management perspective, she has provided management oversight to customer remediation efforts, transaction monitoring reviews and assessments, gap analysis, sanction reviews, work flow and case management product selections, testing, refinement and implementations. In addition, she has assisted clients in calibrating their thresholds and settings within the compliance technologies to accommodate enhancements and augmentations made to the financial institutions' business models.
• Prior to joining A&M, she was at Deloitte, Pinkerton Consulting and Booz Allen and Hamilton.
• Ms. DeMartino earned a dual bachelor's degree in arts and sciences from Syracuse University with honors. She is a frequent speaker on topics related to technologies within compliance and has written several articles on the subject.
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• Peter Kwan is a Director in the Forensic Technology Services practice within Alvarez & Marsal's Global Forensic and Dispute Services line of business in New York. He brings 10 years of consulting experience in the management and implementation of data analytics efforts, BSA/AML Look-back reviews, and strategic database design and implementations
• Currently, Mr. Kwan is performing post-implementation testing for the Internal Audit department of a mid-Western based U.S. bank using the Actimize system. Previously, Mr. Kwan worked on a BSA/AML technology assessment for a large bank in Mexico offering US Dollar repatriation services to their customers.  While at A&M, he has helped clients with regulatory driven Look-backs mandating the screening of transaction counterparties against governmental lists (e.g. OFAC) and the identification of reportable suspicious transactional activity, performing BSA/AML technology assessments on their usage of BSA/AML automated tools (YellowHammer BSA, AML Manager, Banker's Toolbox), and assisted with an implementation of the CDD module of NICE-Actimize.
• Prior to joining A&M, Mr. Kwan worked in the Data Management Group at PricewaterhouseCoopers (PwC). His past project work has focused primarily on the following areas for clients in the Financial Services industry:
  • Anti-Money Laundering:
    • Designed name matching techniques to compare information from wire remittances against the OFAC and sanctioned country lists and performed data analytics to identify transactions with High Risk jurisdictions (specifically Iranian U-Turn transactions) for a large Japanese bank;
    • Implemented interim transaction monitoring tools to identify potential SAR reportable activities for two different South American based banks and the embassy banking division of a global Financial Institution;
    • Performed unification of customers from different lines of business and an enterprise customer risk ranking for a Mid-West regional bank in the U.S.;
    • Performed data modeling, database development, and data analytics for several multi-year look-back engagements;
    • Conducted data quality and integrity reviews of transactional and customer level data;
    • Assisted in the refinement and optimization of AML rule/scenario thresholds
  • Regulatory Reporting: Design & development of an automated data ingestion and reporting tool to generate quarterly FDIC loan loss reports for a mid-Atlantic regional banks
  • Audit Automation: Development of tools to automate Partner Capital Allocation testing for hedge fund audit teams
  • Business Intelligence: Design of a dimensional data model to convert & store and report 5+ years of the data from the Financial Planning & Analysis group of a publicly trade Hedge Fund/Private Equity client. Designed Business Objects specifications to leverage the data model for reporting