Michael Dawson

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+1 202 384 1080 direct
Washington, DC

Previous Experience

  • Founder and CEO, Promontory Risk Review
  • CEO, Promontory Financial Group (UK) Ltd.
  • Deputy Assistant Secretary, U.S. Treasury Department
  • Senior Adviser to the Deputy Secretary, U.S. Treasury Department
  • Chief of Staff and Counsel, FOLIOfn Inc.
  • Associate, Covington & Burling
  • Law Clerk, Judge James L. Oakes, 2nd U.S. Circuit Court of Appeals

Thought Leadership

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Michael Dawson

Managing Director and CEO, Promontory Asia

Michael leads Promontory’s Asia operations. He is a subject-matter expert in financial-crimes risk management, encompassing anti-money-laundering, sanctions, and anti-bribery and -corruption compliance; know-your-customer remediation and transaction reviews; New York Department of Financial Services Part 504 certifications; and issues associated with customer de-risking. He also has experience in leading information-security and data protection/privacy reviews; compliance engagements and reviews related to mortgage servicing and origination and the Servicemembers Civil Relief Act; and implementation of governance, risk, and compliance systems, such as OpenPages, RADAR, Archer, and MetricStream. Michael leads a number of Promontory’s regtech initiatives, including AML & Sanctions Atlas™, RADAR, and a web-based library of compliance obligations and testing scripts. He has worked with traditional financial institutions and fintech firms in locations around the world.


Michael has led a large number of projects since joining Promontory in 2004. Prior to joining Promontory, he served as a senior adviser and deputy assistant secretary at the Treasury Department, where he assisted the deputy secretary in leading an interagency committee of the National Security Council charged with developing counterterrorist-financing strategies; served as the lead policy official on consumer data protection and privacy issues associated with the Fair Credit Reporting Act and Fair and Accurate Credit Transactions Act of 2003; implemented U.S.-Mexico economic-development initiatives involving remittances, foreign direct investment, and nongovernmental organizations; and coordinated the U.S. government’s interagency approach to protecting critical financial infrastructure from physical and cybersecurity threats, along with public-private partnerships including the Financial Services Information Sharing Advisory Council.


  • J.D., Yale Law School
  • M.Phil., economics, Cambridge University
  • B.A., economics, Williams College

Affiliations, Awards, and Civic Engagements

  • Distinguished Service Award, Department of the Treasury
  • Member, Bars of the District of Columbia, several district and appellate courts, and U.S. Supreme Court

Representative Engagements

  • Helped large, complex banking organizations implement enterprisewide compliance risk assessments.
  • Developed and implemented programs for managing third-party and vendor risk.
  • Executed KYC remediation efforts for large, internationally active banks.
  • Conducted look-backs or transaction reviews for money laundering, sanctions evasion, mortgage servicing issues, SCRA breaches, ABC lapses, and other compliance violations.
  • Conducted analysis of consumer complaints.

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