Marie Gervacio

Marie’s relevant leadership experience:

• Trusted Advisor: Advise global and local financial institutions on the impact of overseas and local regulatory requirements and expectations on their Asia operations, including, but not limited to: board governance; enterprise risk management frameworks & internal controls; KYC, AML & counter-financing of terrorism; fraud risk, anti-bribery & corruption; private equity due diligence; family office risk management; IPO sponsorship process risk management; securities & futures commission & Hong Kong Monetary Authority compliance.
• Internal Audit Leader: Provide strategic planning and market coverage; projects included but were not limited to local regulatory compliance for a large European banking group across Southeast Asia, Hong Kong SFC requirements of a large Indian bank, and HKMA and SFC regulatory compliance reviews for several international financial institutions.
• Financial Markets Infrastructure Change Leader: Led several large-scale international banking projects across Asia covering over 10 jurisdictions, to educate and support both buy-and sell-side financial institutions in their understanding and implementation of the effects of the market’s transition away from IBOR rates, as well as the European Securities and Markets Authority (ESMA) Markets in Financial Instruments Directive (MiFID) II, which introduced widespread, systemic change into the European and international financial markets across operations, financial instruments, and trading venues.

Relevant Engagements

Board Governance, Enterprise Risk Management & Internal Control

• Performed internal controls framework review, enhancement, and build, including a significant project at a multilateral development bank based in Beijing, covering large-scale controls uplift of the Office of the Controller: fraud risk assessment and management, policy & framework design/build, ICFR analysis and implementation, target operating model design, loan processing controls uplift, and financial reporting controls uplift.
• Led the gap analysis and uplift of the Risk and Control Self-Assessment (RCSA) process of an international bank, including review of key risk identification, mapping and classification to control libraries, walkthrough and testing of key controls for design and operating effectiveness, mapping to operational risk classifications and risk appetite definitions, proposing solutions, and supporting implementation of controls uplift.
• Performed a comprehensive review of the Operational Risk Framework for the Financial Controller’s function of a large Swiss-based international banking group, including walkthroughs of end-to-end financial accounting and reporting processes, review and documentation of all risks and related controls (including key risk classifications) across four Asia-Pacific jurisdictions, and mapping to management information reporting.
• Advised the C-Suite and “1-down” executives of an international bank on a phased approach to analyzing and improving the over-arching risk culture of the organization, including executive workshops, surveys to gauge risk sentiment, training on “tone at the top” vs. “tone at the middle”, policies and procedures review, and remediation.

Financial & Capital Markets

• Led over 50 operational due diligence (ODD) reviews of private equity fund managers managing impact investment funds in Africa, India, and Southeast Asia on behalf of potential Limited Partners prior to committing capital; reviews included analysis of PE manager governance frameworks, cash management, business integrity and compliance policies and procedures, and other key operational processes, with recommendations for controls and best practice uplift where findings have been identified.
• Led the IPO Sponsor review of a multinational financial institution which was subject to SFC enforcement action for certain due diligence weaknesses or failures in 2019; the review included an end-to-end analysis of the bank’s IPO sponsor business, including related governance, risk frameworks, controls, policies, and procedures, as well as interviewing key investment sponsors and deal teams, and performing a detailed review of a sample of completed IPO deal files; the review resulted in recommendations related to governance, process improvement, controls uplift, and documentation enhancement, with a long-form report submitted to, and accepted by, the SFC.
• Led the MiFID II impact analysis and transformation support of the Asia-Pacific operations of two major global financial institutions, including review of product inventories and end-to-end trade and transaction mapping, as well as cross-functional stakeholder management and project management to achieve go-live on 1 January 2018.

Financial Crime & Bribery/Corruption/Fraud Risk Management

• Advised a rapidly expanding U.S.-based crypto-currency lender on its Financial Crime Risk Management program, including a review of alignment to the FinCen BSA/AML “5 Pillars” guidelines, and recommendations for the uplift of its governance model, KYC process, transaction monitoring process, and SAR process.
• Performed a fraud risk management framework review for the APAC operations of a multi-national financial institution, covering top-down and bottom-up analysis mapping fraud risk exposure, mitigating controls, and gap analysis to regulatory and industry requirements and best practices; deliverables included uplift of the fraud risk assessment and management framework, policy and process controls uplift, and remediation recommendations.
• Led the Asia-Pacific review of a large Australian bank’s AML/CTF and Sanctions framework to create an internal business case for enhancement of their framework controls and technology to obtain head office funding. Led the review of an SFC-licensed Southeast Asian brokerage and asset manager in Hong Kong, including an end-to-end review of compliance with SFC AML/CTF and KYC requirements and expectations, and related remediation implementation to address observations and findings.