Programs that hold. Built by someone who has tested the ones that didn't.
Why Chapter X
Title 31 of the Code of Federal Regulations, Chapter X, is where the Bank Secrecy Act lives: the recordkeeping, reporting, customer due diligence, and program requirements that every examiner reads before they walk into your building. Most compliance failures aren't failures of intent. They're failures to build what Chapter X actually requires, in a form that survives contact with an exam. The firm is named for the standard because the standard is the job.
Who I am
I'm Thaedra Frangos. I've spent thirty years in financial crimes, on both sides of the table.
For nearly two decades I was an investigator: a criminal forensic auditor with the New Jersey Department of the Treasury, a task force officer with Homeland Security Investigations, and an investigative agent with the New Jersey State Commission of Investigation. I worked money laundering, trade-based money laundering, and public corruption cases, testified before grand juries and legislative bodies, and learned what a Suspicious Activity Report looks like when it lands on the desk of someone who has to act on it.
In 2015 I moved to the institutions filing those reports. At Goldman Sachs I investigated terrorist financing, money laundering, and market manipulation and held real-time transaction approval authority for high-risk clients and jurisdictions. At HSBC I served as the enterprise subject-matter expert on money-laundering typologies and built the control-testing methodology adopted across the bank's four regions. At MUFG I led a 25-person second-line testing organization through more than 100 regulatory reviews during a period of heightened supervisory scrutiny, then directed global trade finance financial-crime risk oversight and built the training that went to practitioners worldwide.
Most recently I stood up financial crimes program management from the ground up at a federally chartered Banking-as-a-Service sponsor bank operating under heightened regulatory expectations: the governance, the risk assessments, the document hierarchy, the issues management, the Board reporting, and the examination interface, in a year.
How I work
Second line is my native language. I've spent most of my career testing other people's programs, which means I know where they break: the risk assessment that describes the institution it wishes it were, the policy nobody can find the procedure for, the monitoring rule that was tuned once in 2019, the Board deck that reports activity instead of health. I build to prevent those, not to paper over them.
I'm direct. Institutions under regulatory pressure generally find that restful. You'll get the finding, the reason, and the fix, in that order, in plain language, without the hedging that makes consulting reports unreadable and unusable.
Every engagement is scoped to the institution in front of me. Every program, regardless of scope, is built to the same standard: reasonably designed, risk-based, documented, and defensible under 31 CFR Chapter X and the FFIEC BSA/AML Examination Manual. That isn't a slogan. It's the language the examiners will use when they decide whether you passed.
Who I work with
Fintechs and payments companies preparing for sponsor-bank onboarding or state licensing. BaaS sponsor banks building financial crimes oversight of their partner portfolios. Institutions that have drawn an MRA or enforcement action and need a rebuild rather than a patch. Boards that need to understand what they're actually accountable for. And conference audiences who would rather hear how it's done than how it's described.
Credentials
M.S., Economic Crime Management, Utica College of Syracuse University. B.S., English Literature and Bilingual Education, summa cum laude, Rider University. Certified Anti-Money Laundering Specialist (CAMS), in progress. Member, Association of Certified Fraud Examiners. Financial Women's Association 2022–23 Pacesetter graduate. Author, Trade Based Money Laundering & Terrorist Financing: Methodologies for Combating the Growing Economic and Cultural Threat.
Where I am
Northern New Hampshire, north of the notches. I work with clients across the United States, in person when it matters and remotely when it doesn't.
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