Benay Nachin
Anti-Money Laundering Professional
Pittsburgh,Pennsylvania
Summary
My passion is combating financial crime. Through the adequate implementation of the USA PATRIOT Act and other Anti-Money Laundering laws and regulations, I believe the financial industry can have a substantial impact on financial crime. My objective is to assist financial institutions and Non-Bank Financial Institutions (NBFI) in understanding and achieving the goal of national security and reduction of crime through regulatory responsibility.
Overview
30
30
years of professional experience
Work History
Group Manager
BNY Mellon
05.2021 - Current
- Responsible for successful strategic implementation of KYC overhaul
- Involved in building a Customer Risk Rating methodology with the goal of enhancing the understanding of institutional and non-institutional client risk
- Identified attributes that are to be used in determining risk for all types of clients, including Banks, Funds, Trusts, and Digital Asset Custody clients
- Write use cases and business requirements for Customer Risk Rating technology
Senior Analyst
AML RightSource
12.2020 - 04.2021
- I worked with a fintech client that operates in the payment space
- I was responsible for investigating suspicious activity such as, BTC transactions and equity transactions
- Utilized Chainalysis to review the source and disposition of cryptocurrency transations
- Met my goal of 10 reviews per day
- In this position I prepared SARs on any suspicious activity detected.
Senior Manager
Deloitte
01.2020 - 08.2020
- Assisted a top tier financial institution with their, BSA/AML consent order remediation
- Lead a Foreign Correspondent Bank Know Your Customer (KYC) remediation project for the US branch of a large Foreign Bank Organization (FBO)
- Performed a quantitative staffing needs assessment for the Financial Crimes Prevention unit of a large wholesale bank
- Managed an Anti-Money Laundering, second line of defense quality assurance testing team that conducted testing and monitoring of KYC, Sanctions, and Transaction Testing
- Oversight of a team conducting due diligence of KYC requirements for Funds and Investment Managers who applied for the Term Asset-Backed Securities Loan Facility (TALF) government relief program under the CARES Act for a large Investment Bank
- Developed and managed project plans to ensure deliverables were completed on time
- Managed multiple projects simultaneously.
- Always managed projects on or below budget
Principal Consultant
CAPCO
08.2017 - 01.2020
- Lead a team of 35 contractors in an KYC remediation project for one of the largest wholesale banks in the world
- Developed audit program using the Title 31 Exam Procedures and conducted BSA/AML/Sanctions Independent Review for one of the largest Pawn Brokers in the US for their Precious Metals business
- Developed Sanctions program for the same Pawn Broker for their US business and their international affiliates
- Experience optimizing and validating multiple automated Anti-Money Laundering surveillance systems
- NYDFS Part 504 readiness assessments
- Wrote and reviewed AML policies and procedures.
Assistant Director
FIS
08.2015 - 08.2017
- Interim BSA Officer for a commercial bank that was under threat of consent order by the OCC. No consent order was issued
- Assisted in business development involving identifying needs, discovery conversations, and contract negotiation
- Performed consulting engagements such as BSA/AML/OFAC Risk Assessments, Independent Testing, Alert Clearing, Lookback Reviews, Interim BSA Officer, High Risk Customer Monitoring, etc
- Managed a team of four Senior Compliance Managers which includes performance coaching, scheduling their projects and reviewing their work
- Project management
- Training consisting of speaking engagements and training client’s BSA staff
- Trained and mentored new employees on industry practices and business operations.
- Worked with team leaders to arrange schedules based on production requirements and available resources.
- Created and updated physical records and digital files to maintain current, accurate and compliant documentation.
Chief Compliance Officer
Metro Bank
05.2012 - 05.2015
- Identified potential areas of compliance vulnerability and risk to develop and implement corrective action plans.
- Provided guidance, advice and training to improve business' understanding of related laws and regulatory requirements.
- Developed and implemented the Compliance Management System and mentored the Compliance team to implement the second line of defense monitoring
- Ensured compliance with all consumer regulations, including TILA, ECOA, HMDA, CRA, UDAAP, RESPA, Dodd-Frank, Privacy, etc
- Established regulatory policies and procedures
- Reported the condition of compliance to the Compliance Committee and the Board of Directors
- Chair of the institutions Compliance Committee
- Managed compliance staff
- Oversaw the second line of defense compliance monitoring program
- Responsible for Risk Assessments as they pertained to regulations
- Developed Compliance training
- Oversaw outsourced compliance functions
BSA/AML Officer
Metro Bank
01.2011 - 05.2012
- The bank was under consent order for BSA and reacted by hiring inexperienced staff to perform the BSA functions
- I took the team of 13, none of which had more than a year of experience, and trained, mentored, and developed them
- In the time I was the BSA/AML Operations Manager, 90% of the team were successful in obtaining their CAMS certification
- The bank was also released of their consent order during my tenure in the BSA/AML Department
- Assisted in the development of a sustainable BSA Program
- Managed daily operations of the BSA/AML Group which consisted of Investigations, EDD Monitoring, Regulatory Reporting and System Support
- Developed and implemented BSA/AML/OFAC policies and procedures
- Built the Enhanced Due Diligence Monitoring Program for high-risk customers
- Served on the Account Closure Committee
- Kept current on updates to the Bank Secrecy Act, USA PATRIOT Act and PA State regulations
- Worked closely with Federal and State regulators
- Developed department policies and procedures
AML Audit Manager
Metro Bank
07.2010 - 01.2011
- I was responsible for tracking the consent order remediation and ensuring that the Independent Review Pillar of the AML Program was met
- Managed the BSA/AML internal audit
- Served on various committees
- Performed consumer compliance audits
- Developed audit programs
- Wrote audit reports
- Reviewed policies and procedures
EDD Manager
Webster Bank
04.2007 - 07.2010
- I was an integral part of Webster Bank being released from their BSA consent order
- Managed the high-risk customers corporate-wide, including Private Banking, complex commercial relationships, and Money Services Businesses
- Performed enhanced due diligence for high-risk customers, including MSBs, cash intensive businesses, and third-party payment processors
- Co-Managed 13 Investigators regarding complex money laundering cases
- Member of the Rules Committee for the surveillance software employed by the bank
- Member of the SAR Quality Review Committee
- Responsible for 314(b): Information Sharing
- Lead the development team for the CIP/CDD/EDD automated system
- Managed internal and external exams.
BSA/AML Officer
First Commonwealth Financial Corporation
04.2005 - 04.2007
- Lead the Management team in developing the Anti-Money Laundering Program
- Wrote the AML Program, policy, and procedures
- Conducted a corporate wide BSA/AML/OFAC risk assessment
- Conducted AML training for the Board of Directors and employees
- Monitored for suspicious activity
- Developed the Customer Identification Program and trained all frontline staff
- Performed OFAC and 314(a) follow up on potential matches
- Addressed audit concerns
- Managed internal and external exams.
Compliance Officer
First Commonwealth Financial Corporation
01.1998 - 04.2005
- Provided deposit and lending compliance support
- Prepared and conducted compliance training
- Conducted compliance monitoring
- Advised on compliance issues related to the development of new products and services
- Updated policies and procedures
- Assisted in the regulatory requirements of opening and closing branches.
- Identified potential areas of compliance vulnerability and risk to develop and implement corrective action plans.
- Monitored compliance with processes, policies, procedures and standards in regards to collection and management of annual contributions from shareholder companies.
Internal Auditor
First Commonwealth Financial Corporation
03.1992 - 01.1998
- Developed effective and efficient audit programs that focused on process improvement and identifying areas of risk
- Tested to ensure adequate internal controls were in place and functioning properly
- Performed operational audits of all areas of the bank to ensure adherence to internal policies and procedures, as well as state and federal regulations
- Wrote reports detailing the deficiencies and suggested profit enhancements associated with the function reviewed
- Assisted the external auditors in their annual review of the holding company.
Education
Bachelor of Science - Accounting
Indiana University of Pennsylvania
Indiana, PASkills
AML Expertise
Compliance Program Management
Governance
Internal Audit
Compliance Procedures
Risk Assessments
High Risk Customer Risk Mitigation
Project Management
Microsoft Office
High Risk Customer Risk Mitigation
Compliance Monitoring
Transaction Monitoring
Affiliations
Association of Certified Anti-Money Laundering Specialists
Certified Anti-Money Laundering Specialist – Financial Crimes Investigator (CAMS-FCI), 2018
Association of Certified Anti-Money Laundering Specialists
Certified Anti-Money Laundering Specialist (CAMS), 2005
American Bankers Association
Certified Regulatory Compliance Manager (CRCM), 2000
Volunteer Work
Financial Services Volunteer Corps, New York, New York
Volunteer in Country: Amman, Jordan March 18 and 19, 2007
Held a two-day seminar for the banks headquartered in Jordan. The topic was building a sustainable Compliance Management System. The Central Bank of Jordan had issued a law requiring banks to develop compliance programs. The success of this endeavor required education on best practices in the industry on developing a compliance program.
Volunteer in Country: Moscow, Russia March 2012
Planned, prepared, and delivered training focused on AML typologies for several Russian banks in two different cities.
Timeline
Group Manager
BNY Mellon
05.2021 - Current
Senior Analyst
AML RightSource
12.2020 - 04.2021
Senior Manager
Deloitte
01.2020 - 08.2020
Principal Consultant
CAPCO
08.2017 - 01.2020
Assistant Director
FIS
08.2015 - 08.2017
Chief Compliance Officer
Metro Bank
05.2012 - 05.2015
BSA/AML Officer
Metro Bank
01.2011 - 05.2012
AML Audit Manager
Metro Bank
07.2010 - 01.2011
EDD Manager
Webster Bank
04.2007 - 07.2010
BSA/AML Officer
First Commonwealth Financial Corporation
04.2005 - 04.2007
Compliance Officer
First Commonwealth Financial Corporation
01.1998 - 04.2005
Internal Auditor
First Commonwealth Financial Corporation
03.1992 - 01.1998
Bachelor of Science - Accounting
Indiana University of Pennsylvania