KYC and AML Experience

Developed innovative solution for address quality for wire transfers to meet AML controls. Regulators are signaling potential changes to wire transfer operations by requiring complete and valid addresses for both the sender and the receiver. Kathleen developed a new solution to meet evolving AML regulations for both wholesale payments and cross-border payments.   She designed use cases to measure effectiveness of address validation and presented the solution to senior members of the Federal Reserve Board Bank Secrecy Act (BSA) Committee. (Pitney Bowes 2014)

Drove correspondent bank client selection strategy to “de-risk” the portfolio. Kathleen coordinated with Global Financial Crimes team to create a profile of an “acceptable” correspondent banking client using FATF risk-based approach. Developed a scoring process based on country, products used, credit risk rating, and other variables. She drove a multi-division project team which reviewed each of 2,400 correspondent bank relationships then exited 900+ which scored outside acceptable risk parameters. (Bank of America 2011)

Cash and Banknotes business in Mexico challenged by the DEA. The DEA asked Bank of America to consider exiting the cash and Banknotes business in Mexico because of suspected money laundering of drug proceeds. The Hacienda of Mexico panicked saying an exit by BAC would cause economic stress in Mexico. Then Fed Reserve Chairman, Ben Bernanke, intervened to ask BAC to carefully consider its decision. The Federal Reserve of New York is the agency responsible for USD circulation outside the US. The tug-of-war between politics, law enforcement and regulators put BAC in the middle. Kathleen, the Global Wholesale Banknotes Executive, quickly pulled together a cross-divisional internal team from Legal, Compliance, Ops Risk and Regulatory Relations to review the DEA request. She instituted a unique, enhanced due diligence process for the six banks in Mexico using BAC Banknotes, created enhanced transaction reporting for Mexico-US transactions and tightened operational controls. She met with US and Mexican regulators to present new controls and gain their support. BAC made the decision to remain in Mexico, thereby averting a regional economic crisis. Because of the additional controls, within six months, her team expanded Cash and Banknotes to include a seventh bank in Mexico. (Bank of America 2010)

Drove global expansion for Cash and Banknotes -- 43% growth in 2011.   Two major competitors forced to exit the Banknotes business due to AML violations. Navigated Risk and Compliance governance committees to alleviate concerns related to AML operational controls. Developed relationships with Regulators in the US, Europe and Mexico to dialogue on AML regulations. Instituted Global Operating Committee to monitor AML risk and operational risk. (Bank of America 2010-2011)

Developed innovative solution for AML in wire transfers. Regulators are signaling coming changes to wire transfers by requiring complete and valid addresses for both the sender and the receiver. Developed a new solution to meet evolving AML regulations for wholesale payments and cross-border payments.   Designed use cases to measure effectiveness of address validation. Presented solution to the Federal Reserve Board Bank Secrecy Act (BSA) Committee. (Pitney Bowes 2014)

Posted in Projects and Experience.