Sydney, New South Wales, Australia
A senior executive, with deep expertise in leading risk and governance transformation across complex global financial service businesses and experience operating with C-suite and Board level stakeholders. Adept at partnering with business for innovative solutions, Karen’s industry, regulatory and professional services experience add significant value to an organisation, providing insight into financial and non-financial opportunities. Passionate about diversity, Karen’s professionalism and genuine care for people is a key asset in building and leading high performing teams.
Delivered key financial crime risk transformation programs across Australia and international jurisdictions and multiple industry segments providing the necessary foundation for the business to operate sustainably within a compliant framework, including: • Development and uplift of AML/CTF Programs, supporting risk assessment methodologies, customer due diligence, regulatory reporting and role-based training programs • Development of Global AML Standards within complex and competing regulatory environments. Strong advocate within AML legislative reform and contributed to various ABA and AFMA working groups. Key liaison with AML regulator and supported Board AML engagement. Demonstrated leadership in a complex and ambiguous context, mentoring and coaching staff across various levels of seniority and remit to deliver outcomes.
Led a cross functional team on International Funds Transfer Instruction (IFTI) Reporting review, providing direction and bringing together external counsel, operations and risk to deliver a new reporting standard and a comprehensive assessment against that standard. Provided leadership to transition the project into BAU. Evolved several key Retail AML standards and methodologies to improve standards and worked with Line 1 for success in execution, including: • The Retail Customer Risk Assessment (CRA) Methodology – a composite approach reflecting a more accurate customer risk profile and providing greater process efficiencies; • The Retail Customer Identification Program (CIP) which created a single CIP applicable across the Retail businesses to provide greater coverage and clarity in requirements; and • The Retail Product and Channel Risk Assessment (PCRA) Methodology and Tool for completeness and currency in line with regulatory requirements and industry good practice.
Key engagements have included: • AML/CTF Strategic Initiatives, Customer Due Diligence Enhancements and AML/CTF Remediations International Bank (European): Led the Policy and Procedures stream for an AML/CTF transformational project focusing on initial, enhanced and ongoing CDD reflecting updated risk assessment methodology. Developed AML/CTF procedures aligning to new Global Policy within an organisation facing significant change. • AML/CTF Policy and Program Development Large Domestic Bank: Led the development of AML/CTF Programs and supporting procedures for certain offshore jurisdictions. Created traceability matrices for these offshore businesses against their local and Australian regulatory requirements for transparency across obligations and how the institution addressed these through its respective AML/CTF Programs and supporting procedures.
The AML3 Program was a CBA group wide $90m+ project established to address significant regulatory AML changes, including customer due diligence. Created and led the Risk & Compliance team providing SME support to the project as key changes were made to Group policies, business systems, processes and procedures. This included input to a strategic initiative to create a specialist KYC Hub for complex customers.
• Designed and delivered within 3 months a fully functional AML Program for a diversified financial institution. This program held up to scrutiny from the regulator, 2 AUSTRAC inspections, over 2 years apart and also an independent review by PWC. • Managed a CDD remediation resulting in less than 3% of customers needing to be contacted for further information. Protected the brand, avoided customer complaints and regulatory action. • Worked on major global projects as the local SME within extreme deadlines while managing the Financial Crime team, delivering product and program better fit for purpose for the Australian business and risk environment. • Identified a significant AML horizon risk and worked with the business and external legal for a successful resolution.
Key engagements included: • AML/CTF Strategic Initiatives, Customer Due Diligence Enhancements and AML/CTF Remediations Managed and acted as the SME in several AML/CTF remediation works, with focus ranging from risk assessments, customer due diligence, enhanced customer due diligence, transaction monitoring and governance and compliance frameworks. • AML/CTF Gap Analysis and comparison of Jurisdictions Undertaken many AML/CTF gap analyses domestically and against global policy for foreign and domestic banks in Australia and conducted comparisons of particular jurisdictional AML/CTF requirements. • AML/CTF Training Developed and facilitated AML/CTF training across all levels of staff, including for a global bank’s AML/CTF officers at a conference in China, at board level both in Australia and overseas and for professional industry courses.