MICHELLE BOLEWARE

I've held four positions with Guidehouse with the most recent position being with Coinbase.

I began on the Banco Popular engagement from 10/2019 to 04/2020 as an AML Investigations Analyst.

From 04/2020 to 07/2021 I was on the PayPal engagement as a Loan Origination Specialist and later as a Loan Forgiveness Specialist.

After the PayPal engagement, I rejoined the Banco Popular engagement until 11/2021 and I've been on the Coinbase project as an AML Investigator since then.

• Conduct compliance investigations and analysis in support of Coinbase's BSA/AML and other regulatory compliance policies and programs including investigating transaction monitoring alerts, reviewing transaction and user activity, conducting research, and determining whether activity is suspicious and reportable to FinCEN in a Suspicious Activity Report
• Identify alerting/triggering activity and transactions conducted during the look-back period as well as any prior or current cases associated with the user
• Complete deep transaction analysis as well as blockchain analysis to determine the complete scope and true nature of the alerted activity
• Understand the nature and purpose of the user’s account and complete a holistic review of the user’s profile for any red/green flags that may support or refute the alerted activity
• Identified threats, vulnerabilities and suspicious behavior patterns to recommend mitigation measures
• Responsible for completing all compliance investigations and making U.S
• Based SAR/No SAR decisions, preparing and filing SAR’s within 30 days of determining that an event is suspicious.
• Remain current with industry standards and developments in the areas of BSA/AML, KYC and OFAC, and apply regulatory requirements (e.g., BSA, CDD Rule, Sanctions, USA PATRIOT Act, etc.) and internal policies and procedures to case investigations

• Obtained copies of applicants' credit histories and reviewed paperwork to determine feasibility of granting loans.
• Submitted loan applications to underwriter for verification and recommendations.
• Collaborated with other departments to promptly process loan applications.
• Recommended loan approvals and denials based on customer loan application reviews.
• Observed regulatory, compliance and security policies and procedures to keep data as safe as possible from breaches.
• Maintained strict confidentiality of bank records and client information.
• Self-motivated, with a strong sense of personal responsibility

• Responsible for monitoring and analyzing financial transactions to detect and identify suspicious activity as well as researching and evaluating the identified activity to ensure compliance with applicable local and international laws and regulations
• Detected unusual activity, suspicious/illegal behaviors and patterns
• Maintained a strong understanding of global anti-money laundering regulations and a working knowledge of transaction monitoring systems.
• Prepared reports, metrics and research to support fraud initiatives and projects

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• Reviewed system generated alerts to assess the presence of illicit and suspicious activity that may require reporting based on Bank Secrecy Act (BSA)/AML requirements, conduct research as required to make determination about disposition and further necessary action and document detailed results in written SAR narrative format
• Conducted sensitive Transaction Monitoring Case and SAR Level investigations across a variety of product lines (Retail, Commercial, Foreign/Domestic Correspondent Banking, Credit Cards, etc.) involving Wire Transactions, Credit Card Transactions/Payments, Checks, Cash, Non-cash
• Monetary Instruments, Remote Deposit Capture, and Trade Based Money Laundering
• Performed extensive Enhanced Due Diligence (EDD) research which includes Negative News and sanctions research, analysis of business services and transaction monitoring
• Navigated banking systems to obtain account statements, transaction histories, wire transfer details and check images related to each investigation
• Maintains current knowledge of the Bank Secrecy Act and all related anti-money laundering and OFAC regulations
• Clearly interpret and narrate the suspicious transaction activity for a specific alert
• Identify, mitigate or escalate BSA/AML red flags that caused the alert as per procedures
• Complete Suspicious Activity Reports, file CTR’s, address sanctions alerts, and other applicable AML processes in accordance with regulations and time limitations
• Provide feedback on alert rule effectiveness and partner with management and analysts to design new rules
• Build and maintain awareness of the broader context and implications of the various types of risk affecting the business (e.g., financial, legal, reputation, etc.)
• Validate quality of draft Suspicious Activity Reports via FinCEN Software for various business units (AML Operations, Auto Lending, Savings, Information Security)
• Provide insight into various commercial banking products and services
• Escalate issues as appropriate for advanced investigation and analysis
• Support team supervisors in executing certain responsibilities.

• Verified all aspects of the Client Identification Program (CIP) and all necessary account opening documents that were provided and in accordance with Know Your Customer (KYC) policies and procedures including AML, CDD and EDD
• Completed extensive due diligence investigations using public and private databases in accordance with Anti-Money Laundering (AML), BSA, OFAC and other regulatory standards to assist business units and prevent operational and reputational risks
• Identified accurate risk rating for individual/non-individual accounts to highlight high risk jurisdictions, cash intensive/high risk businesses and Politically Exposed Persons (PEPs)
• Performed checks on all employees, consultants, vendors, contractors and third party advisors using internal and external sources
• Conducted enhanced due diligence research in attempts to find derogatory/background information used to aid client decisions in initiating, maintaining or closing business relationships
• Ensured final reports were comprehensive and compliant for use in the client on-boarding decision-making processes.

• Performed quality control audits on affidavits, declarations, certifications, and notices of default in support of the Motion for Relief
• Ensured timely filing of Motion for Relief and other required supplemental documents
• Assisted in managing the QC1 and QC2 Network audit process for the affidavit group
• Assisted in preparing the month end reports of the Network affidavits that passed QC2 audit review
• Assisted with month end audit reports on front end reps, QC1 and QC2 level review for executed affidavits to ensure all of Bankruptcy local rules and Citi’s policies and procedures were met and in compliance
• Supported manager in performing management functions such as training new reps and review of escalations
• Assisted with drafting timelines and process flowcharts as needed for management and the
• VP of Operations
• Served as Subject Matter Expert and trainer over the Kentucky team on the review and audit process of affidavits
• Assisted in creating and updating the policies and procedures for submission and approval to the change control group for publication on the Citi Source website
• Assisted in the creation and updating of databases for reporting purposes for the affidavit team
• Completed additional special projects and tasks as assigned by management
• Prepared and processed all approved affidavits, declarations, certifications and notices of default for outgoing UPS mail daily.