Cynthia Shea

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+1 512 293 1114 direct
New York

Previous Experience

  • Independent Consultant
  • Director for Policy, Texas Department of Banking
  • Senior Examiner, Special Supervision, Office of the Comptroller of the Currency

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Cynthia Shea

Managing Director

Cynthia advises financial institutions on regulatory and risk management issues, with an emphasis on compliance with U.S. anti-money-laundering laws.


As a leader in Promontory's AML solution center, she works with teams across the globe to propose, devise, and implement solutions for AML and sanctions compliance at a range of financial institutions. She has consulted extensively outside of the U.S., with a focus on clients in Canada and Mexico. She is fluent in Spanish and competent in French and Portuguese.

While at Promontory, Cynthia has led engagements with some of the world's largest financial institutions, as they have enhanced and streamlined their AML and sanctions compliance programs. Clients have ranged from retail banks to complex correspondent and international banking operations. More recently, she has performed groundbreaking analysis related to money-service businesses and applied AML principles to blockchain payment technology and artificial-intelligence tools. She is a primary contributor to Promontory's work with parent company IBM, developing AML 2.0 tools to revolutionize the compliance landscape. In her role as leader of Promontory's core AML solution center, she supports engagements across the globe and provides critical quality assurance.

Prior to joining Promontory, Cynthia held senior positions at federal and state bank regulatory agencies, where she worked on several interagency task forces addressing fundamental supervisory issues. At the Office of the Comptroller of the Currency, Cynthia oversaw a portfolio of banks facing solvency challenges and worked with colleagues at the Federal Reserve and Federal Deposit Insurance Corp. to manage a number of high-profile resolutions. While in this position, she authored a study on bank failures that ultimately influenced the OCC's licensing policy. As a senior official at the Texas Department of Banking, Cynthia reshaped the state's examination process and acted as the agency's ombudsman. She played a key role on the task force that rewrote the Texas Banking Act.


  • B.A., economics and business administration, magna cum laude, Vanderbilt University

Affiliations, Awards, and Civic Engagements

Representative Engagements

  • Led a two-year enhancement and remediation of a global AML program for a non-U.S. bank with operations in Singapore, Latin America, and the Caribbean.
  • Developed AML and sanctions compliance policies and programs for a private-label bank hosting a large population of prepaid-card programs and third-party payment providers, with an additional focus on retail online banking.
  • Performed an AML and sanctions risk assessment supporting the MSB license application for a blockchain payment provider.
  • Defined AML compliance standards and evaluated and enhanced AML controls for a national payday-loan provider.
  • Evaluated the AML controls and practices of a high-risk international banking operation focused on private banking.
  • Advised an association of non-U.S. bankers on optimizing access to the U.S. correspondent-banking system.
  • Helped develop and implement an enhanced AML program at one of the world’s largest retail and trade-banking institutions.

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