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Emerging Trends in Sanctions: The Challenges and Opportunities of New Payment Technologies, Virtual Currencies, and Machine Learning (ML) / Artificial Intelligence (AI)

Sanctions Connect

Date: Friday, January 28, 2022

Time: 11:30 AM – 12:00 PM EST

Duration: 30 minutes

Speakers:
Dr. Prasad Chintamaneni, Managing Director | Treliant, LLC
Michael Saxon, Senior Director | Treliant, LLC

Moderator: Dino Papagiannis, Managing Director | Treliant, LLC

As technologies emerge and mature and new products and services come online, sanctions compliance programs must also improve and evolve. This session will cover developments with new payment technologies, virtual currencies, and ML/AI, and the practical actions that sanctions professionals should take to remain effective.

Fall 2021 was a notable period for guidance about virtual currency, including the publishing of OFAC’s Virtual Currency Brochure and FATF’s guidance on Virtual Assets and Virtual Asset Service Providers (VASPs), which reiterated the broad scope of sanctions and compliance obligations related to virtual currencies. OFAC’s priorities are made clear by additions to its list of Specially Designated Nationals and Blocked Persons of VASPs and digital currency wallet addresses used by sanctions targets, as well as enforcement actions targeting financial institutions processing virtual currency transactions.

At the same time, developments in ML/AI are already improving efficiency by better differentiating between false positives and real risk, automating a significant amount of decisioning. While these tools can be used to the advantage of compliance, they also present particular challenges.

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Dr. Prasad Chintamaneni, PhD

Managing Director, Treliant, LLC

Prasad Chintamaneni is a Managing Director in Treliant’s Global Financial Crimes Compliance practice. He has over 25 years of experience in financial systems, data analytics, model validation, compliance, governance, and risk management.

At Treliant, he has led data analytic teams on several engagements including independent consultancies involving Office of Foreign Assets Control (OFAC) program reviews of an international bank and a U.S. branch of a foreign bank, as well as a suspicious activity transaction lookback of a foreign bank. He has designed and implemented tools for testing effectiveness of name and transaction screening systems, identification of potential circumvention attempts, and analysis of transaction traffic.

He holds a PhD in Computer Science from Vanderbilt University and a MBA in Finance from the Wharton School of Business.

Michael Saxon

Senior Director, Treliant, LLC

Michael Saxon is a Senior Director with Treliant. His leadership experience in the public and private sectors spans over three decades. Michael regularly advises consultants and clients on blockchain technologies; operations and compliance systems in the virtual currency space; processes mitigating anti-money laundering and sanctions risk; and compliance systems and regulatory matters.

Michael is a retired U.S. Army officer, combat veteran, and graduate of the United States Military Academy at West Point. He served on the faculty of West Point for 10 years, culminating in his directing West Point’s ethics education program. Since leaving service, he has led numerous projects that supported many of the most prominent companies in the cryptocurrency space.

Past engagements include: serving as project manager and primary author for a crypto startup “goto-market” compliance risk assessment, road map, and program development project; serving as Interim BSA Compliance Officer for a U.S.-based crypto on-ramp technology provider, responsible for risk assessment and mitigation, program development and assessment, and all financial crimes compliance operations for the U.S. marketplace; and serving as team leader for a global digital currency exchange’s financial crimes investigation project, providing financial crimes investigations support, including investigation procedures, blockchain analysis, suspicious activity report (SAR) writing and reporting, direct and indirect exposure investigations, and quality assurance/quality control.

He has also served as a team leader for a global digital currency exchange’s compliance process improvement initiative with a team of more than 80 investigators, focused on mitigating customer anti-money laundering/Bank Secrecy Act (AML/BSA) risk, leveraging technology and research methods to address account activity and linkage, source of funds, enhanced due diligence, deep web research, and SARs and sanctions. He then served as a senior advisor to the exchange’s Customer Disputes and Regulatory Division, where he analyzed, managed, and scaled customer and third-party dispute functions and related litigation, as well as engagement with state and federal regulators to address inquiries, investigations, subpoenas, and consumer complaints.

Michael has created and conducted blockchain and cryptocurrency training for executives and analysts and presented on blockchain technologies, cryptocurrency, and other virtual assets, as well as ethics, artificial intelligence/machine learning, and robotics.

Michael holds a BS from West Point and an MA and PhD from Indiana University. He holds certifications in interorganizational planning and in organizational strategy.