Case Studies
highlights of our experience
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Served as Chief Compliance Officer for a global digital asset exchange licensed in the US, EU, and Bermuda.
Provided interim CCO services for a technology company providing API and relay services for Ethereum privacy pools and regulated money transmission.
Served as the senior compliance lead for a blockchain intelligence and crypto exchange company.
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Led multiple independent program assessments for various financial institutions’ BSA/AML, OFAC, ABAC, UDAAP, and GLBA compliance programs (including crypto, payments, and neobanks).
Conducted a compliance gap assessment and improvement roadmap for one of the world’s largest digital asset exchanges to help remediate previous Department of Justice Anti-Money Laundering violations and prepare for expanded US licensing applications.
Conducted an AML and prudential risk compliance assessment for a Bermudan digital assets company seeking Class F licensure in Bermuda.
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Advised one of the world’s largest payments companies in mapping their restricted and controlled products and services controls to global regulations and controls. Deliverables included a rubric for assessing illegal products versus controlled products and related payments flows based on geographic restrictions, scenario modeling, and techniques for updating product screening controls.
Provided advice to one of the world’s largest peer-to-peer payments services related to consumer protection and AML compliance operations. Advisory included the development of a consumer protection principles framework, updates to AML (transaction monitoring) and Customer Support policies and procedures, improvement to customer-facing communications and complaints management, and customer support operations.
Established the AML, Sanctions, Consumer Protection, and Anti-Fraud compliance functions for an EMEA payments company looking to expand their operations in a variety of highly-regulated jurisdictions.
Briefed the Department of Justice regarding the sufficiency and appropriateness of a client’s AML, sanctions, and export controls after a gap assessment and the provision of advice related to strengthening AML monitoring and customer controls.
Developed a staffing Target Operating Model for a global payments platform based in EMEA.
Developed a vendor selection framework for a global digital assets platform.
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Led an OFAC-based investigation and remediation into an Indian bank's transactions tied to Iranian, North Korean, Syrian, and Turkish entities across a five-year span.
Assisted an eastern-European bank in assessing its customer risk, specifically reviewing high-risk customers for sanctions, adverse media, and beneficial ownership issues. Executed a targeted lookback of potentially suspicious transactions related to high-risk entities.
Led a KYC remediation project focused on a global financial institution’s high risk customer base in response to an OCC Consent Order that identified systematic deficiencies in the bank’s AML program. Oversaw the analysis, data remediation, and risk profiling of over 6000 bank customers.