Charlotte Metro
Accomplished and transformative financial crimes compliance executive with broad leadership experience including 10 years as the board-designated Chief AML Officer/BSA Officer and experience across all three lines of defense. Demonstrated success in developing and executing strategies that increase efficiencies and optimize the integrity of BSA/AML, fraud and global sanctions compliance programs, to include significant experience in successful consent order remediation, AML and sanctions risk management, risk assessment design and execution, investigations, lookback process management, enterprise AML platform implementation, transaction monitoring development and optimization, audit, and KYC processes. Experienced in implementing these strategies as they relate to retail banking, auto finance, wealth and investment services, insurance, traditional and online bank deposits, trust and fiduciary services, pension, asset management and international lines of businesses. Excellent communicator with proven ability to build and maintain trusted relationships with regulators and negotiate consensus across key stakeholders to achieve appropriate risk management in support of strategic business initiatives.
Responsible for leading the Global Financial Crimes Compliance program for the ~ $950B Consumer & Small Business/Retail Banking line of business, which includes 66 million customers, 3,800 financial centers, and 15,000 ATMs. Accountable for all aspects of financial crimes risk management related to this business unit, including policy and standards development, transaction monitoring coverage and enhancements, KYC program oversight and monitoring, significant case escalations, and de-risking decisions. Quickly established credibility as a trusted advisor to Retail Banking leadership with a focus on providing pragmatic AML strategies that mitigate risk in the portfolio while supporting responsible growth. Additionally responsible for leading Global AML & Sanctions Risk Assessments and serving as the primary subject matter expert for all 8 lines of business on Know Your Customer programs across the firm. Responsible for leading the effort to transform these processes in response to the 2024 OCC Consent Order, including redesign and execution of new AML and Sanctions Risk Assessment and Customer Risk Assessment Methodologies, and comprehensive CDD and EDD enhancements.
Responsible for leading strategy and transformation for the AML program in response to the 2022 OCC Consent Order, to include developing and leading the technology transformation and innovation agenda. Functionally responsible for Enterprise AML & Sanctions Governance and Risk Management functions, including AML & Sanctions policies and standards, risk assessments, training, exam and audit coordination, issues management, board and management reporting, third party risk management; and advisory services. Accountable for managing the budget, financials, and staffing and capacity planning for a department of ~1500 employees and contractors. Additionally responsible for AML & Sanctions Programs for USAA’s Life Insurance Company, Property and Casualty business, and broker-dealer as the board-designated AML & Sanctions Officer for each legal entity.
Responsible for leading and setting the strategic direction for the Global AML & Sanctions program, including eight AML programs for TIAA Bank, affiliated insurance companies, broker dealers, and Europe and APAC programs. Successfully led the efforts to design and implement integration plans for Nuveen and EverBank acquisitions, wherein I was accountable for design and execution of the integration of all AML and sanctions processes into the TIAA Enterprise AML Program, to include the design and execution of the transition from legacy platforms into TIAA’s Actimize system. Responsible for development and delivery of regular reporting to multiple Board Committees regarding the health of the AML Program. Established and maintained trusted relationships with key stakeholders and business leaders resulting in effective collaboration and AML risk management on key initiatives.
Responsible for leading the development, implementation and management of all required programs, policies, procedures and controls to maintain compliance with BSA, AML and OFAC requirements. Currently leading the merger and integration efforts associated with TIAA’s acquisition of EverBank, wherein I am accountable for design and execution of the integration of the BSA/AML and OFAC programs at EverBank into the TIAA Enterprise AML Program, to include: policy and program, risk assessment, and training program harmonization. Also responsible for design and execution of the transition from EverBank’s AML platform into TIAA’s Actimize system. Responsible for successfully leading TIAA-FSB through the closure of the Consent Order issued in 2013. Successfully designed and executed against a comprehensive Action Plan which resulted in material improvements to the CDD, EDD, transaction monitoring, SAR filing, Risk Assessment, and metrics and reporting processes. With a direct reporting line to the Board of Directors, responsible for advising Senior Management and the Board of Directors of key risk and performance indicators regarding the health of the BSA/AML and OFAC program, and emerging compliance issues related to BSA, AML and OFAC. Additionally responsible for leading the transformation of TIAA’s AML Investigations unit from a siloed and inefficient unit, to a mature, risk-based and streamlined Enterprise FIU. Successfully led the program through the implementation of a new comprehensive financial crimes platform (Actimize) across all lines of business. Improved investigative efficiencies by implementing a risk-based triage process to reduce time spent on low-value alerts.
Identified by the BSA Officer to help build, lead and manage the Global AML Investigations Unit from a start-up operation monitoring one line of business to a robust, risk-based program responsible for enterprise-wide AML investigations. Instrumental in the development of strategy, design and implementation of a joint fraud and AML financial crimes investigations unit (FCIU), to include a new case management platform. Currently leading the largest department in Global Compliance and Regulatory Affairs, responsible for the recruiting, training and managing of 26 financial crimes investigators tasked with supporting Ally Financial’s BSA/AML, fraud and counter-terrorist financing obligations across all lines of business; to include deposits, mortgage, and automotive financing. In addition to the investigate functions, also currently responsible for managing Ally's EDD Periodic review process. Responsible for managing the investigations in support of multiple transition service agreements and statements of work related to the sale of the mortgage lines of business. Served as an advisor to the Chief Anti-Money Laundering Officer in the Canadian business line, and managed the investigation of Canadian cases in accordance with FINTRAC standards. Also responsible for providing oversight and guidance for the company’s various fraud investigative units to enhance communication and efficiencies as well as develop uniform investigative and SAR standards. Responsible for developing and tuning the AML scenarios and methodology for the automated transaction monitoring system across all lines of business. Instrumental in clearing matters requiring attention from both regulators (FDIC and Federal Reserve Board) as well as Internal Audit.
Responsible for providing assurance and advisory services for enterprise-wide AML operations for a newly formed Bank Holding Company, to include validation of management action plans in response to multiple MRAs. Developed customized risk assessments and audit programs based on the bank’s unique AML and sanctions profile.
Designed, implemented, and managed the BSA/AML Quality Control department with 25 direct reports and 120 consultants across 4 regional operation centers. Managed the investigation of over 60,000 cases in an effort to meet very aggressive cease and desist remediations. As Subject Matter Expert (SME), assisted senior management in the interpretation of compliance and regulatory laws, requirements, processes and the formulation of corporate anti-money laundering strategies. Actively involved in creating management responses sent to the regulator. Responsible for auditing the AML investigation process to ensure the bank is in compliance with regulatory standards. Responsible for providing feedback to AML operational management on error rates, trending and coaching opportunities identified through the QC process. Identified by senior management to assist with the merger and integration of Washington Mutual’s AML Operations with J.P. Morgan Chase’s Global AML Operations.
Formalized and documented processes and procedures for the BSA/AML program. Coordinated workflow and executed on numerous OTS deliverables. Successfully directed the training and support of 150 off-site telephone-bankers to analyze AML alerts in an effort to meet an enforcement action. Responsible for delivering daily and weekly work-reports to senior management to include employee error-ratios and trends. Based on these reports, identified process gaps and assisted senior management in implementing action plans.