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Michael coordinates Promontory’s global compliance practice. His practice includes 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 is also active in Servicemembers Civil Relief Act compliance and has managed and conducted several SCRA reviews; compliance and reviews related to mortgage origination and servicing; 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
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
led the Treasury’s initiatives on protecting critical financial infrastructure
from physical and cybersecurity threats, supporting the Financial Services
Information Sharing Advisory Council.
- J.D., Yale Law School
- M.Phil., economics, Cambridge University
- B.A., economics, Williams College
- Distinguished Service Award, Department of the Treasury
- Member, Bars of the District of Columbia, several district and appellate courts, and U.S. Supreme Court
- 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.