Michael Dawson

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+81 33 519 1480 direct

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 practices. He has experience in financial-crimes risk management, encompassing anti-money-laundering, sanctions, and anti-bribery and corruption investigations and compliance, including know-your-customer remediation and transaction reviews; 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 implementation of governance, risk, and compliance systems, such as OpenPages, RADAR, Archer, and MetricStream. Michael leads a number of Promontory’s regtech and suptech initiatives, and has advised on regulatory issues associated with fintech startups, including blockchain and payments regulation. He has worked with financial institutions and fintech firms around the world. Michael is based in Tokyo.


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 Washington state, the District of Columbia, several district and appellate courts, and the 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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