Strategic Insights Delivered
Advisory Services
Description
Before a BSA/AML and OFAC sanctions program gets built, rebuilt, or remediated, someone has to establish what the institution actually needs: its products, rails, and partners; its regulatory posture; and the gap between the program it has and the one examiners will expect to find. This workshop is that step.
It's a structured, one- to two-day working session with your leadership, BSA Officer, and the product, operations, and technology owners who will live with the outcome. We work through the program against the standard examiners actually apply, reasonably designed, risk-based, documented, and defensible under 31 CFR Chapter X and the FFIEC BSA/AML Examination Manual, and we leave with a plan that fits your institution rather than a template.
Who it's for
Institutions that need a program, not a policy binder: a fintech or payments company preparing for sponsor-bank onboarding or state MSB licensing; a BaaS sponsor bank standing up financial crimes oversight of its partner portfolio; or an institution whose existing program has drawn an MRA or enforcement action and needs a clear-eyed view of what a rebuild involves before committing to one.
How it works
Before the session. A focused document request and a short pre-read: existing policies and risk assessments, product and partner inventories, recent examination or audit findings, and any open regulatory commitments.
In the room. Facilitated review of the program across the five pillars: risk assessment, governance and controls, BSA Officer and Board oversight, training, and independent testing, plus the areas that separate a sponsor bank or payments company from a traditional institution: partner due diligence and oversight, transaction monitoring and sanctions screening across ACH, wire, and card rails, SAR governance, and Travel Rule and funds transfer recordkeeping. The goal is a shared, unvarnished picture of where the program stands and what examiners will see.
Afterward. A written strategic assessment and roadmap: prioritized gaps and their regulatory significance; the target program design at the level of policies, controls, staffing, and technology; sequencing and dependencies; and a scoped, priced proposal for the build or remediation phases that follow. Delivered within 5 business days of the session.
Scoped to your institution. Non-negotiable in substance.
Risk assessment. An enterprise BSA/AML and OFAC risk assessment methodology, quantitative and qualitative, producing bank-wide, product-level, and partner-level residual risk conclusions that drive the rest of the program.
Governance and documentation. Board-approved BSA/AML and sanctions policies, supporting standards and procedures, and the document hierarchy that holds them together: governance charter, taxonomy, approval authority matrix, renewal cycle, change management, and regulatory horizon scanning.
Internal controls. CIP, CDD/EDD, and beneficial ownership; transaction monitoring and sanctions screening design and tuning governance; SAR and CTR decisioning and filing governance; 314(a)/314(b), funds transfer recordkeeping and Travel Rule; OFAC screening, blocking, and reporting. For sponsor banks: partner due diligence, risk rating, ongoing monitoring, and offboarding criteria.
BSA Officer and Board reporting. KRI/KPI dashboards, issues management and root-cause remediation framework, and Board- and committee-level management information that shows program health rather than activity counts.
Training. Role-based curricula for the Board, senior management, and first-line teams.
Independent testing readiness. A second-line monitoring, QA, and testing framework, with the evidence trail examiners and independent testers will ask for.
Talks on BSA/AML, sanctions, sponsor-bank oversight, and TBML from someone who has investigated it, tested it, built it, and defended it to examiners.
Every program I've stood up started with the same cornerstone: a risk assessment that told the truth, a document hierarchy that could hold weight, and controls that did what the policy said they did. The talks come from that work, not from a slide library.
Financial crimes compliance is usually presented one of two ways: as a regulatory checklist, or as a war story. Neither helps a room of people who have to go back on Monday and run a program. I speak from the investigation table, the second-line testing floor, the sponsor-bank program office, and the chair across from the examiner, in plain language, with the stakes intact.
Audiences include compliance conferences, fintech and payments events, bank boards and board committees, industry associations, and graduate programs in financial crime and risk. Formats range from a forty-minute keynote to a half-day closed-door session for a Board that needs to understand what it's actually accountable for.
Talks I give
The Other Side of the Table. What thirty years as an investigator, tester, and program head taught me about how examiners read a program, and what they're really asking when they ask for your risk assessment.
Twelve Months to a Program. Standing up financial crimes program management from nothing at a BaaS sponsor bank under heightened regulatory expectations: what to build first, what to defer, and what you can't.
Sponsor Banks, Fintechs, and the Oversight Gap. Why partner-bank models fail on the compliance side, what the enforcement record says, and what a defensible partner-oversight program looks like from both seats.
Trade-Based Money Laundering, Still. The typologies that move value through invoices and shipping documents, why they survive every new technology, and what a program can realistically detect. Based on published research and work directing global trade finance financial-crime risk oversight.
After the Order. What a consent order, MRA, or monitorship actually does to an institution day to day, and how leadership teams get through remediation with the program, and the people, intact.
Every talk is tailored to the room. If your agenda needs something that isn't on this list, ask.
Laying the cornerstone
Thirty years in financial crimes compliance and law enforcement: nearly two decades investigating money laundering, trade-based money laundering, and public corruption for state and federal law enforcement, including grand jury and legislative testimony; financial crimes roles at Goldman Sachs, HSBC, and MUFG, where I built and delivered global trade finance financial-crime training to practitioners across four regions; and most recently standing up financial crimes program management at a federally chartered BaaS sponsor bank. Published on trade-based money laundering and terrorist financing. Financial Women's Association Pacesetter graduate.
Logistics
Based in northern New Hampshire; available in person across the U.S. and virtually anywhere. Starting at $500, fees vary with format, audience, and preparation; [association and academic rates available]. Send the date, the audience, and what you need the room to walk out knowing.
Committed to Measurable Impact
The practice integrates rigorous analysis with industry expertise to deliver comprehensive strategies tailored to each client's operational realities.
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