The USA PATRIOT Act and Anti-Money Laundering

Lisa D. Arquette, currently Chief of the FDIC's Anti-Money Laundering (AML) Section, joined the FDIC in 1990. During her career, she has served as a Safety and Soundness Examiner, Senior Capital Markets Specialist and Review Examiner. In her current position as Chief of the AML Section, she also represents the agency as a member of Treasury's Bank Secrecy Act (BSA) Advisory Group and the FFIEC's BSA/AML Working Group. She has been responsible for administering a nationwide program on the BSA/AML policies.

Arquette has a master's degree in Business Administration from the University of Houston and a bachelor's degree in Criminal Justice from New Mexico State University. She also is a graduate of the Stonier Graduate School of Banking, Georgetown University, Washington, D.C., and is a Certified Anti-Money Laundering Specialist.

Connie Fenchel served as the Deputy Director, Operations and the Executive Assistant Director of Law Enforcement Policy for the Financial Crimes Enforcement Network (FinCEN) from 1999-2003.  Ms. Fenchel oversaw the operating programs and regulatory policies of FinCEN and she was responsible for ensuring that FinCEN’s programs and policies effectively supported federal, state, and local law enforcement investigations and initiatives.  She led FinCEN’s effort to administer the recordkeeping, reporting and anti-money laundering provisions of the BSA and USA PATRIOT Act more effectively and efficiently.  Ms. Fenchel reorganized the operational offices within FinCEN to strengthen its partnerships with its stakeholders and customers including the financial supervisory agencies, federal and local law enforcement and the regulated financial community.  Ms. Fenchel conducted numerous training seminars throughout the United States and internationally for law enforcement personnel, and the financial industry on money laundering, the BSA and the USA Patriot Act.  She also led delegations to international conferences and multi-lateral meetings throughout the world.

As the Executive Director of Operations for U.S. Customs Service (USCS), Office of Investigations, Ms. Fenchel was responsible for the direction and oversight of all investigations conducted by USCS Special Agents, including smuggling, illegal export and money laundering investigations.  During her tenure as Director of Operations, Ms. Fenchel directed the largest undercover money laundering investigation in U.S. history.

Prior to forming The Dominion Advisory Group in May, 2005, David B. Caruso was the Executive Vice President, Compliance & Security of Riggs Bank NA. In June 2003 he was hired to build a regulatory compliance, investigations, and security department in response to 2003 enforcement action against Riggs. Mr. Caruso led the development and implementation of a BSA/AML program across all consumer, commercial, investment, and international business lines. Mr. Caruso was responsible for reporting on the bank's efforts to resolve its regulatory challenges to the Board of Directors, senior examination and headquarters staff of the OCC and Federal Reserve, senior law enforcement officials and the staff of several Congressional committees.

While at Riggs Mr. Caruso oversaw the investigation of Augusto Pinochet's alleged money laundering and the corruption involving senior government officials of Equatorial Guinea. 

Prior to joining Riggs, Mr. Caruso was a director at two big four accounting firms where he led anti-money laundering compliance and fraud investigations practices. Prior to consulting, Mr. Caruso was the manager of the anti-money laundering and enhanced due diligence group at JP Morgan & Company.

Mr. Caruso began his career as a Special Agent with the U.S. Secret Service where he was assigned to the New York Field Office's Financial Institution Fraud group. He received his BA from the George Washington University.

Jamie L. Boucher is a counsel in Skadden’s Financial Institutions Regulatory Group with a principal focus on financial institution mergers and acquisitions, regulatory and enforcement matters. Ms. Boucher represents U.S. and non-U.S. banks, thrifts, insurance, securities and investment companies. 

In the last several years, Ms. Boucher has worked on regulatory matters including: 

AmSouth Bancorporation in a deferred prosecution agreement and regulatory settlement and combined $50 million forfeiture and civil monetary penalty; 

Ms. Boucher regularly represents financial institutions on compliance and enforcement matters, examinations and voluntary disclosures involving federal and state regulatory and enforcement agencies with respect to the bank regulatory laws. With extensive experience in the Bank Secrecy Act (BSA), as amended by the USA Patriot Act, and the economic sanctions laws administered by the U.S. Department of Treasury’s Office of Foreign Asset Controls (OFAC), Ms. Boucher has counseled domestic and foreign financial institutions on numerous issues arising under BSA, OFAC and related laws. She has worked extensively with clients to design and implement internal compliance programs, conduct internal investigations, train company personnel, and monitor and improve corporate compliance posture. Ms. Boucher is a frequent speaker at seminars on financial institution compliance and regulatory issues, mergers and acquisitions and enforcement matters. 
 

Prior to joining the firm, Ms. Boucher worked for 12 years in government and the private sector on matters involving international trade and investment regulation. She has served as the legislative advisor for international trade and foreign policy to Senator Frank H. Murkowski (R-AK), a member of the U.S. Senate Foreign Relations Committee; as an advisor to the American League for Exports and Security Assistance on trade and national security issues; and as a committee staff member on the U.S. Trade Representative-Department of Defense trade policy advisory committee, the Defense Policy Advisory Committee on Trade. Ms. Boucher currently serves as the vice-chair of the American Bar Association Banking Law Committee, Subcommittee on Mergers and Acquisitions. She is a member of the American Council of Young Political Leaders. 

J.D., Georgetown University Law Center, 1996 (cum laude)

Ken Isaacson is a legal, financial, and business consultant, a BSA/AML legal and regulatory expert, and a BSA/AML Consultant on the USA PATRIOT ACT Title III and the Bank Secrecy Act of 1970. He has twelve years of practical and theoretical knowledge on anti-money laundering. Specifically, to the current BSA/AML landscape, he is an expert on BSA/AML Look-Back Projects with project management, project lead, and analyst capabilities, and specializes on developing risk management strategies for banks, asset managers, and financial businesses in outsourcing/offshoring BSA/AML functions. Prior to becoming a consultant he was the President and Chief Legal Officer of an investment due diligence company that specialized in anti-money laundering due diligence checks as one facet of the company’s core metrics. His expertise extends to the Code of Federal Regulations, OFAC policies, procedures, and practices, and the OCC. He is adept at SEC laws and regulations, NASD, NYSE, and corresponding jurisdictional laws and regulations on the regulation of financial institutions. He has performed compliance checks and developed compliance KPI systems for financial institutions. He is a recognized speaker on compliance, having authored papers on the subject, and has one training manual on compliance in the process of being published.

Former Acting Director, Bureau of Revenue, Customs and Taxation, Republic of Palau, former Chief General Counsel, Department of Law, City of Dayton, Ohio.

Mr. Sklar has over 20 years experience in the MSB Industry and has lectured and provided extenstive training to MSB's on AML issues, locally, nationally and internationally. He has been at the forefront of the Independent Reviews for MSB's as well as employee training and developing written internal controls, policies and procedures. He currently chairs the ACAMS MSB Taskforce as is Chair of the Metro NY ACAMS Chapter

Mr. Landrum retired as a Special Agent with the IRS Criminal Investigation Division after almost 28 years with the agency.  He conducted numerous investigations of money laundering and financial fraud violations ranging from drug trafficking organizations to corporate officers.  He was also one of a select and highly trained group of agents chosen to work in an undercover capacity which he did for almost ten years, specializing in money laundering activity.  Mr. Landrum worked many years with the Organized Crime Drug Enforcement Task Force where he assisted in dismantling major drug organizations by "following the money". 

Throughout his career Mr. Landrum has been recognized by numerous agencies for his work, including the FBI, U.S. Attorney's Offices, IRS and other enforcement agencies.  His experience includes working inside money laundering as an undercover agent, investigating money laundering as a government agent and assisting clients from the defense perspective as a financial crimes consultant.

Robyn brings a wealth of compliance and legal experience to bear on meeting clients’ needs. She is a former compliance executive with Bank of America, and in-house counsel with two of its predecessor institutions. Regarding anti-money laundering compliance, her areas of focus included consumer and commercial banking, non-bank financial institution such as Money Services Businesses, and higher risk customers. She is a Certified Anti-Money Laundering Specialist, a Certified Six Sigma Green Belt in process design and implementation, and is a licensed attorney in four states. Robyn is a former Trial Attorney with the United States Department of Justice, and a former Assistant United States Attorney for the Northern District of Georgia, assigned to the Presidential Organized Crime Drug Enforcement Task Force.