Richard has demonstrated his experience on multiple anti-money laundering (AML), sanctions/ The Office of Foreign Assets Control (OFAC), Foreign Account Tax Compliance Act (FATCA), and Foreign Corrupt Practices Act (FCPA), with a strength in Society for Worldwide Interbank Financial Telecommunication (SWIFT) message analytics. More specifically he has assisted clients in identifying their exposure to compliance, fraud, and corruption issues.
Richard’s professional experience includes:
- OFAC sanctions lookback of middle-eastern institution. Richard presented findings to OFAC, DOJ, FBI, IRS, and SDNY government agencies. Focus was around 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. The review included millions of SWIFT messages, hundreds of thousands of trade finance files, and millions of book-to-book transfers. Richard was part of the senior leadership team responsible for overseeing execution for the investigative protocols and methodologies, report preparation, and project strategy. His 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 individual’s communications data. His team was further able to reduce the reviewable population by applying advanced analytics technology to the dataset, allowing reviewers to focus on inclusive content and providing the means for a small review team to get through several million records in a short time frame.
- Internal investigation into trade finance transactions involving sanctioned parties on the US SDN/OFAC lists. Assisted European institution with extracting trade documentation and SWIFT messages from multiple archive versions of SWIFT Access Alliance (SAA) and reconstructing the trade finance activities. This allowed centralized data analytics to be applied across all in-scope transactions. Determined US nexus and connection with targeted SDN/OFAC screening, to determine exposure. Conducted eDiscovery review across key custodians to determine level senior management involvement and the control environment in place.
- OFAC sanctions investigation into a global financial institution. SWIFT 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. These messages were then linked in a bespoke social networking program to reconstruct the full transaction and all messages associated. This ensured that a complete picture was available for both a qualitative and quantitative standpoint. Richard managed a global team across all workflows involved, requiring developmental, operational and strategic decision making at key stages of the engagement. The project also required implementation of review software, integration with historic SWIFT archiving libraries, and complex data cleansing and aggregation for centralized analysis. This was rolled out to four external locations using a combination of client and third-party infrastructure.
- AML and sanctions compliance review. A financial institution was faced with allegations of implementing insufficient measures to prevent the facilitation of money laundering by its clients and limit its exposure to sanctions violations. Outside counsel was appointed to perform an independent compliance review and provide evidence-based counseling on the matter. Ankura supported counsel by providing forensics, transactional analytics, and eDiscovery support, in the review of the bank’s records. Assessing culture, conduct, and events relating to financial crime were paramount, with Richard involved in communications to key stakeholders.
- Part of the Independent Examiner (IE) team responsible for auditing a data request of a Swiss private bank. This related to the FATCA influenced agreement between the US DOJ 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 analyzing 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.
- Review of client and account Know Your Customer (KYC) records of a major US asset manager. A team of 125 AML 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. Richard was the site lead in the London office.