It’s been exactly two years since my first day on Wall Street, where I was plucked from the nonprofit world to support the Sanctions and Embargoes program of a large financial firm. On that first morning I was told that “making it through the day without getting indicted is not an acceptable standard”. I took this to mean that banking’s carefree days of brushing off compliance obligations were long gone – which I can’t imagine is news that will upset many people.
What I found instead is an incredibly knowledgeable and diverse team of experts who work well together, and above all, make office life a fun and collaborative environment. Plus the views over both the Hudson and East River were not too shabby either.
Throughout my tenure I got to work closely with US regulators, particularly the Office of Foreign Asset Control (OFAC), to ensure adequate Sanctions controls for the bank. I’ve learned a great deal, worked on some really interesting cases and investigations, and gained a new appreciation for the work it takes to enforce controls in such a large, global institution with millions of customers.
I got to work on some exciting projects over the past two years, some of which I’ve sampled below:
Risk Management, MI & Data Analytics
I’ve worked closely with US regulators to meet anti-financial crime and compliance requirements, and advised business lines and corporate clients by providing subject matter expertise and guidance with regards to sanctions laws and obligations. This required extensive and ongoing risk assessment and management along with strong data analysis to back it up.
In addition to enhancing MI, I created an entire client risk framework from scratch. This enabled me to review suspicious client activity and to flag key client risks and trends – all of which were communicated in detailed reports to regulators. The MI that I created was eventually set forth as a global standard to be replicated in the Bank’s other operating regions.
Project & Exam Management: 3rd Party Fed Review
Commissioned by the Federal Reserve, the bank engaged an independent review of its compliance program that required the extensive audit of documentation and periodic interviews with staff. As part of the project management team, I coordinated workstreams, tracked targets and facilitated discussions across departments to ensure the timeliness and accuracy of deliverables.
Governance
I’ve enhanced the Bank’s governance structure to ensure adequate control and oversight over Sanctions and Embargoes matters within the Americas region. This required the creation of standing committees and review forums, as well as a concise escalation paths for risks and issues. I’ve also written policy frameworks, Rules of Procedure and desktop procedures for governance Councils in the region.
Maria Polychronis 