Independent Consultant

3/07 — Present
Focus on supervisory, regulatory and enforcement matters, as well as anti-money laundering issues, pertaining to financial institutions.

Clients have included:

International Monetary Fund

American Express

American Bankers Association

Association of Certified Anti-Money Laundering Specialists (ACAMS)

Bryan Cave

Bank of America

9/06 — 3/07
Senior Vice President, handling BSA policy issues.

Financial Crimes Enforcement Network (FinCEN)

6/05 — 6/06
Contractor for the Regulatory Policy and Programs Division, handling BSA policy issues, cases and drafting of regulations.

Office of the Comptroller of the Currency (OCC)

12/83 — 5/05
Assistant Director of the Enforcement and Compliance Division

7/86 — 12/86
Legislative Counsel

6/80 — 12/83
Senior Attorney

9/75 — 6/80
Attorney

Additional Legal Positions

7/02 — 11/02
Rotational assignment to Main Treasury to assist in writing regulations implementing the USA Patriot Act.

7/87 — 2/88
Acting General Counsel for the District of Columbia’s Office of Banking and Financial Institutions.

9/809/81
Special Assistant United States Attorney assigned to the Fraud Section of the U.S. Attorney’s Office in Washington, D.C.

Awards

Received the OCC’s 2004 Bank Supervision Award on 4/20/05 “in recognition of . . . exceptional contributions to [the] fulfillment of OCC’s bank supervision responsibilities.”  Award was given for my review and guidance with regard to all Bank Secrecy Act issues set forth in the Reports of Examination of the large national banks.

Received the Secretary of the Treasury Albert Gallatin Award for having over 20 years of service with the Department of the Treasury.

Received the Secretary of the Treasury’s Award in 1999 for work on a case involving a major fraud in a national bank.

Received the OCC’s Chief Counsel’s Award “for extraordinary legal contributions to the achievements of the Office of the Comptroller of the Currency during 1986” for my work on the T. Bertram Lance case.