Preparing for Sudden and Planned Changes to your Sanctions Program: Tips & Strategies

Amber Vitale is a Managing Director at FTI Consulting in New York City specializing in sanctions and anti-money laundering compliance. She brings multiple perspectives and insights to projects based on 20 years of experience in diverse roles, including at OFAC, financial institutions, law and consulting firms.

Amber offers deep expertise to OFAC investigations, enforcement matters, and litigation. She has been a sanctions expert and liaison to investigators and prosecutors at the U.S. Departments of Commerce, Justice and State, and the Manhattan District Attorney’s Office.

Prior to joining FTI Consulting, Amber worked at the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) for five years, most recently as an Enforcement Section Chief, investigating and resolving thousands of cases involving services and goods in the financial, oil and gas, shipping, agricultural, medical, and many other industries. More recently, Amber was Head of Sanctions Advisory at Brown Brothers Harriman & Co., responsible for global sanctions policy and procedures; OFAC reports, guidance, and training; and lists and critical data for screening, and sanctions-screening settings.

Previously, she developed global polices and conducted OFAC investigations as the Senior Compliance Officer for Economic Sanctions and an Assistant General Counsel at AIG International. As an Associate at Schulte Roth & Zabel LLP, Amber advised banks, insurance companies, money-service businesses, broker-dealers, investment advisors and hedge funds on AML, OFAC and anti-bribery/corruption compliance. She was also as a Director at a Big Four consulting firm where she developed and led AML and OFAC-related remediation projects for financial institutions.

Ellen Hewitt is a Senior Managing Director in FTI Consulting’s Risk & Investigations practice. She supports domestic and multinational clients in resolving issues arising from fraud and malfeasance, sanctions and compliance failures, government regulation and enforcement, as well as event-driven crises. She has deep experience conducting internal investigations, transaction reviews, due diligence appraisals, and systems evaluations and compliance controls testing related to the Bank Secrecy Act (“BSA”), anti-money laundering (“AML”) and the Office of Foreign Assets Control (“OFAC”).

For the past ten years, she has provided investigative research and risk consulting services for matters stemming from regulatory enforcement actions, pre-transactional due diligence, activist investors, and asset traces. She has also managed ongoing in-depth, multi-jurisdictional due diligence and asset search investigations into international and domestic subjects using a wide range of public records, commercial databases and human source inquiries.

Prior to joining FTI Consulting, Ms. Hewitt worked as an analyst at a geopolitical risk consulting firm, where she conducted investigative research and risk assessments through open source intelligence research and source inquiries in English and Russian.

Jesus S. Ornelas is a Managing Director in FTI Consulting’s Financial Services practice based in New York City. His expertise and skills include knowledge of Anti-Money Laundering, Know Your Customer, the Bank Secrecy Act and Office of Foreign Assets Control (“OFAC”) regulatory policies.

Since joining FTI Consulting, Mr. Ornelas has been a contributing leader in a wide range of engagements with multinational banks, money services businesses and financial services companies. He has consulted clients on evaluating the risks and emerging trends of money laundering, terrorism financing and sanctions. He has assisted clients in responding to regulatory action as a result of examinations, cease and desist orders and matters requiring attention. He has also completed numerous forensic transaction lookback reviews as part of government investigations. Mr. Ornelas has conducted independent reviews of client policies and procedures, state regulatory exams, risk assessments, suspicious activity report (“SAR”) logs, investigations logs, currency transaction report (“CTR”) lists, training programs and internal controls. He has assessed financial institutions’ compliance program governance and management oversight programs, including design and effectiveness of governance structures and frameworks.

Prior to joining FTI Consulting, Mr. Ornelas worked for JPMorgan Chase and supported its global compliance operations group in the corporate sector. There he managed a team of analysts, responsible for supporting and leading initiatives under the firm’s AML Program. His team was responsible for tracking and analyzing quality of case investigations and filing appropriate SARs. He also collaborated with business operations managers and external monitors to establish procedures and develop organizational structure for the firm’s case investigations remediation teams. In his role, he also provided and used effective training programs to easily understand general principles and concepts underlying a particular program as well as developing staff skills.

In 2013, his role included support of the rollout and launch of the NICE Actimize financial crimes investigation portal for Global Compliance Operations. There he assisted the team with alert rule testing and appropriately updating policies and procedures. This included working with independent monitors to ensure proper adherence to laws and regulations. The project also involved establishing training for new team members and ensuring proper quality control as new alert rules were introduced to the program.

Mr. Ornelas has a Bachelor of Arts in Business Management from California State University Fullerton, Mihaylo College of Business and Economics. He is a CFE, CAMS certified, and is also fluent in Spanish.

Ivy Llena has over 14 years of experience in the learning and development field, providing capacity-building and professional development programs for corporate and social service agencies in the US and the Philippines.

Before joining ACSS, she was a program director at a non-profit organization in the Philippines, where she co-designed and co-implemented economic empowerment programs and services for survivors of human trafficking and their families. Ivy also served at the Social Policy Institute at Washington University in St. Louis, where she led and contributed to inclusive economic growth initiatives.