RESOURCES
Sanctions Risk in Capital Markets: An Evolving Paradigm
Financial institutions’ exposure to risk from the US government’s use of international sanctions is escalating today—managing sanctions risk can be particularly challenging in capital markets.
OUR SERVICES
OFAC Advisory Services
- OFAC Risk Assessments
- OFAC Policy & Procedures Design, Development & Implementation
- OFAC Screening Software Implementation & Fine-tuning including data architecture, false positive reduction and model validation
- OFAC Policy & Technology Gap Analyses
Model Implementation & Validation
- Fiserv, SAS and various In-House Screening Tools
- Fircosoft Products including Trust & Continuity
- FIS PRIME, Penley & IAT
- Lexis-Nexis Bridger & IBM Identity Insight
- eGifts, Safewatch & Total Screening
Independent Consultancies & Monitorships
- Independent Testing of OFAC Controls
- Independent Lookbacks and Reporting to FinCen
- Assistance with Blocking & Reporting of Assets
- Enhanced Due Diligence of Suspect Transactions
Anti-Bribery & Corruption
- Anti-Bribery & Corruption Program Design & Implementation
- Internal Investigations
- Assistance with Self Reporting
- Enhanced Due Diligence of High-Risk Partners/Agents
OUR TEAM
Monica MacGregor
Managing Director
Monica MacGregor is a senior professional with over 20 years of experience specializing in the areas of Anti-Money Laundering and Sanctions, Anti-Corruption, Internal investigations, and Global Risk Management.
During the course of her career, she has led a number of OFAC remediation efforts at both US and foreign banks in response to enforcement actions including Cease and Desist Orders and Consent Decrees. She has conducted several detailed look backs of contemporaneous OFAC screening activities, resolved potential matches and confirmed false positives, and ultimately reported potential matches to OFAC. Mόnica has also conducted OFAC risk assessments for a number of institutional clients with varying risk profiles and assisted in the design and implementation of risk-based, enterprise-wide OFAC procedures.
Mόnica has similarly assisted clients in conducting internal investigations evaluating potential FCPA violations particularly in the US, Mexico and Brazil. She has designed and remediated FCPA and Anti-Bribery and Corruption programs to ensure risk mitigation commensurate with her client’s international operations and business structures in the pharmaceutical, medical equipment and food industries.
Prasad Chintamaneni
Managing Director
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 an MBA in Finance from the Wharton School of Business.
Ross Marrazzo
Managing Partner
Ross Marrazzo is Managing Partner of Treliant. He is also responsible for the firm’s Global Financial Crimes Compliance service area. Ross has over 35 years of domestic and international experience in the design, oversight, and assessment of corporate and regulatory compliance, Anti-Money Laundering/Bank Secrecy Act, Economic Sanctions/Office of Foreign Assets Control, anti-fraud, and anti-bribery/corruption programs, along with operational risk management. He possesses a thorough knowledge of executive and operating functions and responsibilities within public companies and the financial services industry, including for corporate compliance, consumer and commercial banking, investment banking, insurance, and securities. Ross has held compliance and audit executive positions within a number of institutions, covering a wide range of geographical locations, including at GE Capital; First Niagara Financial Group; The Depository Trust & Clearing Corporation; Citigroup; and The Travelers. He has also worked in the securities industry on public and private offering compliance, and as an examiner at the New York State Securities Division.
Ross has extensive experience in designing compliance programs and in remediating and testing controls to remediate regulatory issues, including working with U.S., state and foreign regulators. Through his international experience, Ross possesses a broad understanding of foreign regulatory expectations and culture. Ross’ U.S. government agency experience includes working with the DOJ, FRB, OCC, CFPB, SEC, FTC, and FINRA, along with state banking, securities, and insurance government agencies. He has led large teams on independent consultancies and monitorships for federal and state government agencies, involving U.S. and foreign institutions and their U.S. operations covering AML/BSA and Economic Sanctions/OFAC compliance and fraud issues encompassing multiple jurisdictions worldwide.
Ross is a graduate of St. John’s University and is a Certified Fraud Examiner.
Gino Ercolino
Director
Gino Ercolino is a Director in Treliant’s Securities & Investment Management Compliance, Corporate & Regulatory Investigations, and Global Financial Crimes Compliance service areas. He has 25 years of experience as an attorney and financial regulator, serving in various leadership roles. Gino assists broker-dealers and registered investment advisors with satisfying their securities compliance and regulatory program obligations. He works with various financial institutions to manage all phases of enforcement, regulatory, and corporate investigations. In the global financial crimes compliance space, Gino advises clients on Anti-Money Laundering (AML)/Bank Secrecy Act (BSA), Anti-Bribery and Corruption (ABC)/Foreign Corrupt Practices Act (FCPA) and Office of Foreign Assets Control (OFAC) regulatory remediation, compliance and governance obligations, and risk management.
During his career as a securities regulator, Gino managed teams of attorneys, investigators, and examiners in hundreds of financial investigations. He supervised all phases of investigations, negotiations, settlements, and disciplinary hearings concerning violations of federal securities laws and self-regulatory organization (SRO) rules. Throughout his career, Gino has also provided guidance on compliance requirements and rule interpretation.
Prior to joining Treliant, Gino held senior roles at the Financial Industry Regulatory Authority (FINRA) and New York Stock Exchange (NYSE). As Enforcement Director with FINRA, he managed complex investigations involving areas such as compliance and supervision, sales practices, AML/Customer Identification Programs (CIP), fraudulent activities, advertising, email retention, data privacy, mutual funds, annuity transactions, trading practices, and financial accounting. Gino also served as FINRA Enforcement’s Liaison to State Securities Regulators, managing relationships and communications between various regulators and FINRA. Prior to that, he was Senior Counsel with FINRA and Trial Counsel with the NYSE, where he focused on complex and high-priority investigations and litigations. Gino started his career in private practice as a commercial litigator in a Boston law firm.
Gino holds a Juris Doctor, cum laude, from New England School of Law, an LLM in Banking and Financial Law from Boston University School of Law, and an undergraduate degree from Seton Hall University. He also earned a Certified Regulatory and Compliance Professional (CRCP) designation from the Aresty Institute for Executive Education at the Wharton School, University of Pennsylvania. Gino is admitted to practice law in New York, New Jersey and Massachusetts.
Leslie Kuester
Manager
Leslie Devereaux Kuester has deep expertise in sanctions compliance from corporate, financial institution, and government perspectives. Her 15 yearlong career has touched all aspects of sanctions compliance programs including risk assessments, control development and implementation, due diligence, filter calibration, investigations, engagement with regulators, and associated reporting.
Prior to joining Treliant, she was a Senior Manager at Boeing, tasked with enhancing its economic sanctions program. She was the Global Head of Sanctions and Interdiction for Western Union where she was responsible for ensuring compliance with applicable sanctions regulations in over 200 jurisdictions. She worked at the U.S. Department of the Treasury’s Office of Foreign Assets Control for 10 years where she most recently served as a Section Chief in the Sanctions Compliance & Evaluation division. There she oversaw responses to inquiries on the hotline, administered the blocked assets reporting program, and conducted investigations of financial institutions, among other duties. She also participated in the CSS exam development process.