Background
Bob is a principal in KPMG’s Forensic Advisory Services practice in New York. Bob has worked as a risk and compliance professional for more than 25 years. Prior to joining KPMG in 2011, Bob served as Americas regional head of anti-money laundering for a large international financial institution, including its New York Branch. Bob has also served in a senior capacity in the Legal & Compliance Department of a large US broker-dealer, including serving as Deputy Director of Compliance and Regulatory Counsel. Bob began his career as an attorney in the Enforcement Division of the U.S. Securities & Exchange Commission.
Professional experience
Bob has led many engagements involving AML and Sanctions compliance matters at KPMG, including:
- A large US financial institution retained KPMG to perform an assessment of the institution’s AML and OFAC compliance program after receiving a number of material findings in an OCC examination. Under the engagement, KPMG reviewed the institution’s overall AML Program, including AML strategy; organizational structure; experience level of key AML personnel; core client risk rating, transaction monitoring & OFAC screening systems; data quality oversight; AML transaction monitoring, investigations and SAR reporting; and AML training. KPMG’s observations and recommendations were presented to the institution’s senior management, as well as the OCC. After completion of the review and in anticipation of a possible enforcement action, the institution retained KPMG to assist in addressing identified deficiencies in order to enhance the institution’s AML and OFAC compliance program. In part, through these actions, the institution was not the subject of a public enforcement action.
- Led an assessment of the AML processes relating to one of the largest U.S. bank’s affiliates & intra-company accounts including the identification of such accounts across lines of business and a review of specific AML processes and controls including enterprise-wide AML risk assessments, KYC, transaction monitoring, negative media and sanctions screening as they related to affiliates & intra-company accounts.
- In the wake of a regulatory enforcement action, led a review of transactional activity by the customers of a U.S. custodial banking institution/broker-dealer in order to identify potential suspicious activity involving low-priced securities. In the engagement, KPMG conducted research on over 300 issuers, as well as clients and other control persons. Further, KPMG assessed transactional activity by the financial institution’s customers against reported market activity in order to identify “red flags” associated with market manipulation and unregistered securities. In instances in which unusual activity was identified, KPMG drafted SARs for the client’s consideration.
- Led a Look-back required by an OCC Consent Order involving a large global financial institution. In this role, KPMG “supervised and certified” the quality of SARs filed by the financial institution over several years.
Recent publications and speaking engagements
Co-Author, The Panama Papers: Playbook for Future Response - Crisis Management for Financial Institutions, ABA Bank Compliance Magazine, November/December 2016.
Panelist - AML and Sanctions Crisis Response: Risk-Based Approaches, 2016 ABA/ABA Money Laundering Enforcement Conference.
Representative industries
- Banking
- Securities
- Insurance
Education, licenses and certifications
- Juris Doctor cum laude, Syracuse University College of Law
- Bachelor of Arts with honors in history, Gettysburg College
- Bar Admissions: New York Appellate Division, 2nd Department; State of Connecticut