Richard Chalk is a Managing Director at Ankura, based in London. He has with over ten years’ experience and plays an integral role in providing expert advice around data driven events, including financial crime and compliance investigations; litigation, insolvencies; valuation disputes; management consulting; and general distressed situations.
Richard specializes in structured data arising from business information systems and has run risk review projects and provided complex data analyses to a range of Global 500 clients. His clients are domiciled in the United States, European Union, and Asia. Richard has led engagements involving widely-recognised and bespoke financial and transactional databases to assess risk controls, compliance reporting, processing work-flow, and overall data integrity. His experience includes both database creation and analysis. He is involved in the development of business intelligence reporting systems, innovations in e-discovery review tools, and advanced analytics initiatives.
Richard assisted a large US law firm to undertake a comprehensive OFAC sanctions lookback of a large, Middle Eastern bank. This resulted in Richard presenting findings to OFAC, DOJ, FBI, IRS, and SDNY government agencies. The lookback included 10 years of transactional activity regarding its US dollar clearing and related activity through US and non-US banks, including trade finance activities and book-to-book transfers with possible US dollar clearing. Richard was part of the senior leadership team responsible for overseeing project management, business process, and protocol documentation, the definition of matching/checking algorithms, test plan development, and execution for the investigative protocols and methodologies, report preparation, and project strategy. In addition to the transactional lookback, the team also assisted the law firm with reviewing the bank’s activity related to OFAC compliance from a conduct perspective in the form of reviewing key individuals’ communications data. An on-premise environment allowed the legal team to conduct their review within the bank’s offices without any sensitive data leaving the bank’s control. Email threading and near-duplicate technology were applied to the dataset, allowing reviewers to focus on inclusive content and reducing the review population. Richard’s work also included producing relevant information, first to local financial regulators and ultimately to the Department of Justice and the US Treasury’s OFAC division.
Richard was part of the independent examiner (IE) team responsible for auditing a data request of a Swiss private bank. This related to the Foreign Account Tax Compliance Act (FATCA) influenced agreement between the US Department of Justice and the Swiss Federal Department of Finance in producing information around US related accounts. Richard was responsible for auditing and validating all technical aspects of identifying accounts based on the prescribed US indicia and ensuring the Bank produced all requested account and transaction level information in-line with the program. This involved analysing a large number of database queries across multiple platforms (CRM, account holder, transactional) and ensuring all results were reviewed and integrated into the final production.
A major US asset manager engaged Richard to provide assistance in performing a review of client and account KYC records. A team of 125 anti-money laundering professionals was deployed across six countries (US, UK, Luxembourg, Ireland, Jersey, and Guernsey) to undertake file reviews over a period of four months. A project office was established to monitor workflow across teams, leverage multiple time-zones, escalate process improvement suggestions, and disseminate process and procedure updates. Tactical databases were developed to track file allocations and cases where file remediation was required. Remediation requirements were reported by relationship manager, risk, and client type. Process efficiency was enhanced by activity such as leveraging client KYC across multiple accounts (where risk type permitted), allocation of files categorized by client type.
Richard was involved in an investigation into a global financial institution in relation to OFAC sanctions violations. SWIFT interbank communication messages were extracted, processed, and reviewed to identify transactions non-compliant to the sanctions list. Over one billion messages were reduced to 150 million messages. Over 14 countries were involved in the investigation. Messages were screened against SDNs/PEPs/customised listings in an effort to uncover suspicious payments. These messages were then linked in a bespoke social networking program to reconstruct the full transaction and all associated messages. Richard managed a global team across all workflows involved, requiring developmental, operational, and strategic decision making at key stages of the engagement. SWIFT message knowledge is substantial as a result of the complexities surrounding a review of this magnitude. The project also required implementation of review software, integration with historic SWIFT archiving libraries, and complex data cleansing and aggregation for centralised analysis. This was rolled out to four external locations using a combination of client and third-party infrastructure.