PAUL C. AFFENITA
Palm Harbor,USA
Summary
Dynamic compliance leader with extensive experience at Citibank, excelling in regulatory change management and risk assessments. Proven ability to develop innovative compliance programs and train teams, ensuring adherence to complex regulations. Adept at interfacing with regulators and fostering a culture of compliance while driving business growth.
Overview
26
26
years of professional experience
Work History
Product Compliance Officer (Senior Vice President)
CITIBANK, N.A.
Tampa, USA
06.2019 - Current
- Advised Citi Commercial Bank (CCB) on compliance matters, the drafting of compliance policies and procedures, and provided credible challenge and innovate solutions
- Lead for Regulatory Change Management for CCB - Monitored, analyzed and disseminated regulatory update information, perform gap analysis between policies and regulatory updates, and tracked action plans to close any gaps
- Lead for the Regulatory Inventory Mapping project for CCB. Mapped all applicable laws, regulations, and rules to CCB and partnered with the In-Business Controls team in mapping controls to mitigate Compliance risk.
- Knowledge in commercial banking and brokerage laws/regulations (e.g., Bank Holding Act, Federal Reserve Act [section 23 A/B], Federal Reserve Letter Regulations, CFTC, SEC rules, Dodd Frank Act, FINRA rules, privacy (CCPA, CPRA) laws and some international compliance and privacy laws and regulations, such as GDPR, MiFID II, Market Abuse Regulation, and Bribery Act of 2010.
- Conducted Compliance, AML, Fair Lending, and Anti-Bribery & Risk assessments
- Dodd Frank Act (Title VII- Swaps), Anti-Bribery & Corruption, and Gifts & Entertainment Subject Matter Expert
- Developed and implemented Plan of Supervision and written supervisory procedures for the investment banking activities
- Established offices of supervisory jurisdiction (OSJ), developed a plan to bring CCB employees from the public side to the private side, which included email surveillance and on-boarding personal trading accounts, and ensure that appropriate CCB employees were FINRA licensed
- Proactively worked with the business groups to maintain a balance between business growth and corporate and regulatory requirements
- Developed Compliance training programs and provided Compliance training
- Served on the New Activity Committee. Reviewed new products from a Compliance perspective
- Interfaced with internal audit
- Develop and implemented a Compliance Program, drafted New Product Committee Procedures, Regulatory Change Management Procedures and Monitoring Procedures, and developed Key Risk Indicators
- From July 2014 to September 2017, position was located at the Long Island City, NY office
- Managed a staff member of one (1) while in Long Island City
Regulatory Compliance Officer (Vice President)
RAYMOND JAMES FINANCIAL, INC.
St. Petersburg, USA
10.2017 - 06.2019
- Developed, implemented and managed the Compliance Risk Assessment program across the firm
- Major participant in the development of the Compliance Risk Taxonomy
- Knowledge of banking (e.g., Bank Holding Company Act, Federal Reserve Act, and Federal Reserve letter regulations) and broker-dealer laws, regulations, and rules (e.g., Securities Exchange Act of 1934, Investment Company Act of 1940, Investment Advisers Act of 1940, Dodd Frank Act, FINRA rules, UK Financial Control Authority, GDPR and CCPA)
- Lead partner in mapping applicable banking, broker-dealer laws, regulations, and rules to the lines of businesses for the purposes of Compliance Risk Assessments
- Conducted compliance testing
- Collaborated with the project team in the implementation of Refinitiv Financial Solutions f/k/a Thomson Reuters’ Governance, Risk and Compliance (GRC) tool, Connected Risk
- Major participant of assessing potential vendors for GRC systems and niche Compliance systems
- Lead in the development and implementation of the Key Risk Indicators (KRI) and Key Performance Indicators (KPI) programs. Partner with the Business Unit Compliance officers in the development in KRI and KPI programs
- Interfaced with the Federal Reserve Bank of Atlanta examiners and internal audit
- Managed a staff member of one (1)
Regulatory Compliance Officer (Vice President)
CIT GROUP, INC.
Livingston, USA
09.2011 - 07.2014
- Developed, implemented, and managed Compliance, AML, Sanctions, and Enterprise Risk Assessments processes firm-wide
- Managed the Risk Assessment and Control Assurance team, consisting of two (2) staff members
- Lead partner with the Law Department in developing an inventory of applicable laws and regulations
- Developed Risk Taxonomy for Compliance and Risk
- Project manager for the implementation of Compliance systems and databases
- Provided counsel to the business Compliance Officers
- Developed and managed the control assurance process
- Conducted compliance testing
- Developed, implemented, and managed a Regulatory Change Management program.
- Monitored, analyzed, and disseminated regulatory update information, perform gap analysis between policies and regulatory updates, and tracked action plans to close any gaps
- Interfaced with Federal Reserve, FDIC examiners, and internal audit
- Knowledge of commercial banking laws/regulations (e.g. Bank Holding Act, Federal Reserve Act [section 23 A/B], all Federal Reserve letter regulations (Regulations A-YY), FCPA, confidential information, privacy laws, FINRA rules, Securities Exchange Act of 1934, Investment Advisors Act of 1940, Dodd-Frank Act, and some international compliance laws and regulations.
- Provided compliance training to other Compliance Officers
Regulatory Compliance Officer (Vice President)
BANK OF TOKYO-MITSUBISH UFJ
New York, USA
05.2010 - 08.2011
- Developed and conducted Compliance Risk Assessments
- Reviewed the entire Dodd-Frank Act and conducted an impact analysis
- Developed, implemented, and managed a Regulatory Change Management program
- Monitored, analyzed and disseminated regulatory update information, perform gap analysis between policies and regulatory updates, and tracked action plans to close any gaps
- Served on the New Product Committee. Reviewed new products from a compliance perspective and suggested controls to address compliance risks
- Served on the Information Technology Review Team to review new IT initiatives from a regulatory compliance perspective to determine and address compliance risks
- Interfaced with Federal Reserve, New York State and FDIC examiners, and internal audit
- Knowledge of Dodd-Frank, commercial banking laws/regulations
- Provided compliance training to other Compliance Officers
Policy Manager/Counsel (Vice President)
BARCLAYS BANK, PLC
Jersey City, USA
06.2009 - 05.2010
- Policy Manager for the Financial Investigation Unit (FIU) of Barclays Corporate, New York Branch
- Developed policies and procedures relative to Anti-Money Laundering (AML), Combating the Financing of Terrorism (CFT), USA PATRIOT ACT, data privacy, information security, records management and special investigations
- Counsel to FIU on matters relative to AML, CFT, unlawful internet gambling and special investigations
- Served on the Suspicious Activity Report panel
- Interfaced with Federal Reserve examiners and Internal Audit
- Responsible for action plans to close audit issues
- Developed and maintained AML and Sanctions assessments and controls
- Developed and conducted Compliance training for FIU staff
Senior Counsel (Director)
MERRILL LYNCH & CO, INC.
New York, USA
08.2006 - 03.2009
- Global Disclosure
- Supervised the monitoring, calculation and reporting of Merrill Lynch positions as required by Sections 13(d) and (f) and Section 16 of the Securities Exchange Act of 1934 and other industry regulations
- Assistant Manager of the Global Disclosure unit, which consists of four (4) staff members
- Project manager to develop a new firm-wide Global Disclosure system
- Coordinated the integration of processes, position data and data systems in connection with the Bank of America/Merrill Lynch merger
Compliance Officer (Vice President)
MERRILL LYNCH & CO, INC.
New York, USA
08.2006 - 03.2009
- Regulatory Change Management
- Developed, implemented, and managed the Regulatory Change Management (RCM) process.
- Managed RCM unit consisting of two (2) staff members.
- Knowledge in broker-dealer laws, regulations, and rules (e.g., Securities Exchange Act of 1934, Investment Company Act of 1940, Investment Advisers Act of 1940, FINRA [NASD] & MSRB rulebooks)
- Responsible for drafting, editing and reviewing compliance policies and procedures (e.g. Gifts & Entertainment, AML/PATRIOT ACT (KYC), Foreign Corrupt Practices Act, data privacy and supervision)
- Project Manager for technology implementation to improve the RCM and Policy management processes
- Assistant Manager of the Regulatory Update and Policy & Procedures unit consisting of eight (8) staff members
- Developed and managed the NASD 3013 (FINRA 3030) process (testing and certification regarding written compliance policies)
- Provided compliance training to other Compliance Officers
Regulatory Compliance Officer (Vice President)
CITIBANK, N.A.
Harrison, USA
05.2003 - 08.2006
- Advised the Citi Commercial Banking businesses on compliance matters
- Knowledge in commercial banking laws/regulations
- Proactively worked with the business groups to maintain a balance between business growth and corporate and regulatory requirements
- Developed and managed the Compliance Risk Assessments
- Conducted Compliance Testing
Litigation Associate
BEE READY FISHBEIN HATTER, LLP
Mineola, USA
02.2003 - 05.2003
- Responsible for all aspects of civil litigation
Litigation Associate
GOLDSTEIN, TANENBAUM, LLP
Carle Place, USA
01.2001 - 02.2003
- Responsible for all aspects of civil litigations (commercial, personal injury and medical malpractice)
Litigation Associate
MCCARTHY & KELLY, LLP
New York, USA
10.1999 - 01.2001
- Responsible for all aspects of civil litigation
Education
Juris Doctor Degree -
ST. JOHN’S UNIVERSITY SCHOOL OF LAW
Jamaica, NY06.1999
Bachelor of Arts Degree -
HOFSTRA UNIVERSITY
Hempstead, NY12.1994
Skills
- Advisory & Credible Challenge
- Regulatory Inventory Mapping
- Risk Assessments
- Risk Taxonomy
- Regulatory Change Management
- Training
- Monitoring
- Testing
- Knowledge of Laws and Regulations
- Dodd Frank
- New Product/Activity Committee
- Managed Employees
- AML/Sanctions
- Project Management
- Interfaced with Regulators & Audit
Core Capabilities
- Advisory & Credible Challenge
- Regulatory Inventory Mapping
- Risk Assessments
- Risk Taxonomy
- Regulatory Change Management
- Training
- Monitoring
- Testing
- Knowledge of Laws and Regulations
- Dodd Frank
- New Product/Activity Committee
- Managed Employees
- AML/Sanctions
- Project Management
- Interfaced with Regulators & Audit
Timeline
Product Compliance Officer (Senior Vice President)
CITIBANK, N.A.
06.2019 - Current
Regulatory Compliance Officer (Vice President)
RAYMOND JAMES FINANCIAL, INC.
10.2017 - 06.2019
Regulatory Compliance Officer (Vice President)
CIT GROUP, INC.
09.2011 - 07.2014
Regulatory Compliance Officer (Vice President)
BANK OF TOKYO-MITSUBISH UFJ
05.2010 - 08.2011
Policy Manager/Counsel (Vice President)
BARCLAYS BANK, PLC
06.2009 - 05.2010
Senior Counsel (Director)
MERRILL LYNCH & CO, INC.
08.2006 - 03.2009
Compliance Officer (Vice President)
MERRILL LYNCH & CO, INC.
08.2006 - 03.2009
Regulatory Compliance Officer (Vice President)
CITIBANK, N.A.
05.2003 - 08.2006
Litigation Associate
BEE READY FISHBEIN HATTER, LLP
02.2003 - 05.2003
Litigation Associate
GOLDSTEIN, TANENBAUM, LLP
01.2001 - 02.2003
Litigation Associate
MCCARTHY & KELLY, LLP
10.1999 - 01.2001
Juris Doctor Degree -
ST. JOHN’S UNIVERSITY SCHOOL OF LAW
Bachelor of Arts Degree -
HOFSTRA UNIVERSITY