Nadia Leonova

Oversees and enhances the Anti-Corruption and Financial Crimes (i.e., AML and sanctions) compliance program for Deloitte Global with the objective to provide holistic end-to-end risk management, including development of policies, processes and guidance related to testing, risk assessment, training and communication, and risk identification.

• Manages a geographically dispersed team of ten, and defines the team build-out strategy, including workload assignment, budgeting, recruitment, development, and performance management
• Leads the daily operations and efficiencies of a portfolio of multiple concurrent efforts to (1) ascertain compliance of Deloitte firms internationally with applicable requirements, (2) produce optimal risk management outcomes, (3) ensure resource allocation efficiency.
• Delivers senior leadership reporting and briefings highlighting core accomplishments and changes, emerging risks, and mitigating strategies and assures leadership support of the team’s new programs.

Advanced the agency's goals of safety and soundness and mortgage market resiliency by analyzing and investigating data collected from regulated entities and closely working with their liaisons to ensure transparency in approach to financial crimes compliance (including fraud), data collection and analysis, and reporting; served as a subject matter expert on current and emerging underlying risks and regulatory standards.

• Planned and led the execution of AML regulatory exams and monitoring activities (~2-3 concurrent efforts) at regulated entities, prepared reports of findings and recommendations.
• Provided supervisory oversight support to the agency’s divisions on financial crimes related matters, including policy development, examination approach and guidance on related complex issues.
• Recruited and trained junior team members on program requirements and monitoring procedures.

Led accurate and timely execution of the portfolio of financial crimes-related internal investigations and special projects (~7-10 concurrent efforts) stemming from regulatory action and/or self-identified issues, while managing customer impacts and ensuring adherence to established milestones. Managed a team of 25 employees

• Improved front line remediation process by 90% by designing and implementing integrated remediation framework, establishing strong governance practices, documentation requirements and reporting routines, and enabling consistent quality execution.
• Ensured compliance of corrective action work with applicable AML and other risk management policies by coordinating with independent risk management and internal audit, resulting in 100% adherence.

Oversaw all OCC AML/BSA Consent Order deliverables related to the Wholesale Financial Crimes Risk Management Program, while advocating and communicating on the Financial Crimes Program's behalf to senior leadership, line of defense partner groups, and the Board’s Risk Compliance Oversight Committee.

• Supported Consent Order Responsible Officer in meeting Examiner in Charge's deliverables, ensuring compliance and successful completion of remediation project.
• Established priorities and monitored remediation progress of 14 risk-related work streams within remediation project plan; and facilitated timely resolution of process gaps through effective stakeholder engagement, resulting in 100% on-time project delivery.
• Increased transparency by providing regular updates to Board Committee on remediation progress.

Played a key role in the development, implementation, and monitoring of enterprise-wide Anti-Bribery & Corruption (ABC) compliance program, used the outcome internal investigations to enhance the corporate policy and implementing procedures, to assure compliance with the applicable laws and regulations and to manage the Bank’s bribery and corruption exposure.

• Supported business partners with ABC related reporting, policy interpretation, and key strategic initiatives requiring input from a corporate risk level.
• Led the ABC due diligence stream of the US$32B GE Capital acquisition globally, identifying compliance risks and reporting observations to senior leadership, and provided input into the integration plan to ensure ABC policy compliance.

Managed complex international money laundering and forensic accounting investigations into alleged fraud, corruption and regulatory violations at large multinational companies operating in banking and other sectors. Directed reviews of financial crimes risk management programs, and validation of regulatory and audit issues.

• Ran US$ 1.5-5M budget projects timely achieving scheduled goals and milestones. Successfully managed cross-functional teams located in U.S., Russia, Germany, Switzerland, Belgium, and France ranging from 5 to 50 individuals.
• Led lookback investigations for four major international banks with US$1B in average volume of in scope transactions conducted through networks of correspondent banks and involving parties in Russia, Latvia, Eastern European countries, and offshore locations; developed up to 15 distinct risk profiles to assess vulnerability of financial institutions.
• Uncovered evidence of international fraud and corruption for an aggregate amount of ~US$10M.
• Managed forensic account analysis related to allegations of violations of U.S FCPA and U.K Bribery Act in Germany, Russia, and other European countries, and assisted with subsequent settlement negotiations with the enforcement agencies reaching up to US$1B.
• Effectively directed complex international KYC/CIP remediation engagements with up to 10,000 in scope customer profiles for multinational banks in response to Written Agreements, Consent Orders and MRAs seeking to ensure compliance with regulatory requirements. Prepared clear and concise progress reports to document status and to ensure timely completion of work.
• Consulted two European Central Banks (the Central Bank of Cyprus and the Central Bank of Russia) in efforts to evaluate effectiveness of jurisdictional AML policies, including KYC/CIP requirements, oversight and enforcement. The developed findings and recommendations were used to strengthen regulatory environments

Directed multiple fraud and corruption investigations and U.S FCPA due diligence engagements for companies, operating in banking, manufacturing, and consumer products sectors, and seeking to expand their presence into the Russia and former USSR. Managed and developed teams up to 30

• Promoted within 6 months from joining