It is the aim of the GR Taskforce for such relationships to provide opportunities for regular two-way communication with agencies, such as: the Office of Foreign Assets Control (OFAC), The Office of Financial Sanctions Implementation (OFSI), the European Commission, the U.S. Department of State and the US Department of Commerce BIS, as well as other equivalent agencies world-wide.
Amber Vitale specializes in OFAC and anti-money laundering (AML) matters. Amber has more than 17 years of experience that includes roles in OFAC enforcement, in-house compliance, legal practice, and consulting from which she brings multiple perspectives and insights to projects involving financial crimes-related regulation and compliance, and risk management and internal controls. She is adept at assessing compliance programs, identifying regulatory concerns, providing holistic and risk-based guidance, and developing tailored solutions for clients. She offers deep expertise to OFAC investigations, enforcement matters, and litigation. Amber has been a sanctions expert and liaison to investigators and prosecutors from federal, state and local agencies, such as the U.S. Department of Commerce, U.S. Department of Justice, and 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), most recently as an Enforcement Section Chief, where she investigated cases involving financial services, oil and gas, shipping, electronics, agricultural, medical, and other industries. More recently, Amber was the Head of Sanctions Advisory at Brown Brothers Harriman & Co., where she was responsible for global sanctions policy and procedures; OFAC reports, guidance, and training; and the risk-based review of sanctions lists and screening system settings. Previously, Amber developed global anti-financial crime polices and conducted OFAC investigations as the Senior Compliance Officer for Economic Sanctions and 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 and created various documents for these programs. She also served as a Director at a Big Four firm where she developed and led AML and OFAC-related remediation projects for financial institutions subject to regulatory orders. Amber’s relevant experience includes: assessing the global sanctions program of one of the world’s largest asset managers and custodians, and developing a Target Operating Model with an implementation roadmap; advising the New York branch of the world’s largest multinational bank regarding FircoSoft implementation, including drafting a Business Requirements Document and Tuning/Testing Reports, and creating test cases and data for Functional Performance and User Acceptance Testing; and conducting an independent review of the governance and oversight structure for a global European-based financial institution pursuant to consent order. In addition, Amber performed an enterprise-wide assessment of a global investment firm’s OFAC screening including documentation and gap analysis of existing controls, with recommendations for enhanced screening and other risk-mitigating measures. Subsequently, she created a KYC Data Requirements Policy with recommended documents the client should obtain based on its customers’ individual or entity type to perform required procedures for AML and OFAC compliance.
Shaswat K. Das
King & Spalding
Shas advises clients on U.S economic/trade sanctions (OFAC), anti-money laundering requirements, and export control regulations. In addition, Shas has vast expertise, both from his time in government and private practice, advising on a range of regulatory and compliance issues facing banks, hedge funds, investment advisors, mutual funds, and accounting firms. Shas has experience representing clients before OFAC, USTR, Commerce (BIS), SEC, PCAOB, FINRA, and the OCC. His clients include large financial institutions, Fintech companies, and multi-national manufacturers and distributors.
Shell International Ltd (UK)
Stuart Gamester has been building and managing Ethics & Compliance processes for over 25 years in various multinational companies and also with Government Legislators, such as the Export Control Organisation and HMRC. Highly experienced in Import / Export controls, Sanctions, AML, ABC, with a UK/EU/US/Asia angle. Stuart has developed and managed restricted party / KYC screening tools, built compliance processes and systems for trade / customs, risk assessment and management and is a qualified auditor (working with UK Government and multinational defence, pharmaceutical and oil & gas companies). Out of work Stuart still tries to play cricket and is a Kent Cricket Club qualified coach, coaching at youth level.
Brandon Lee is a Vice President at Goldman Sachs within the Government Sanctions Group. He advises Goldman Sachs’ business units regarding sanctions regulations administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) , UK HM Treasury, and the European Union. Previously, he worked at OFAC in the Enforcement and Policy Divisions. He earned a Bachelor’s Degree in Finance from Hampton University and a Master’s in Business from the University of Maryland, College Park.
Daniel Maloney is a former OFAC Sanctions Investigator and now leads sanctions and trade restrictions compliance at Protiviti. Over the past 10 years, Daniel has held multiple positions at the U.S. Departments of Treasury, Commerce, and State where he gained experience in global sanctions, corruption, human rights, due diligence, export controls, non-proliferation, and conflict minerals. Daniel attended John Jay Criminal Justice in New York where he earned a Masters and Bachelors in International Crime and Justice. During his studies he focused on international crime, human rights, and non-proliferation.
Eric J. Rudolph
Export Controls, Sanctions & Trade
Eric Rudolph is a Managing Director in the Export Controls, Sanctions & Trade practice at FTI Consulting, and he is based in New York. His work focuses on compliance with U.S. economic sanctions and export controls. Mr. Rudolph assists companies by managing the risks associated with sanctions and export controls, with a focus on risk-based assessment of compliance needs, compliance program design, investigations, audits and reviews, and support of remediation activities. Mr. Rudolph has led, managed and participated in compliance reviews in North America, Europe, Middle East, Africa and Asia, and he has significant experience in working with companies operating under government-appointed compliance monitors. Mr. Rudolph’s experience includes advising clients on compliance with various sanctions programs administered by OFAC; risk assessments and review of compliance programs and procedures; and investigation and remediation of potential violations.
Clay Stevenson is an independent consultant specializing in economic sanctions matters, assisting clients in a variety of industries navigate the challenges of fast-changing requirements. Prior to starting his consultancy, from 2009 to 2017 Clay was Managing Director and the Global Economic Sanctions Executive for Bank of America Corporation, responsible for the company’s economic sanctions and anti-boycott compliance efforts, as well as a stint leading its anti-bribery / anti-corruption and Code of Ethics programs. From 2007-2009 Clay had responsibility for economic sanctions compliance at Merrill Lynch. And from 1999-2007, Clay served with the Department of the Treasury’s Office of Foreign Assets Control (OFAC), working first in the Compliance Division and later what is now the Office of Global Targeting, the group responsible for OFAC’s sanctions designation activities. Among his roles while at OFAC, Clay served as the first Chief of the Counter-proliferation Section within the then-Designation Investigations Division where he led a team of sanctions investigators charged with targeting the assets of weapons of mass destruction proliferators and their support networks, with particular focus on North Korea and Iran. Clay received his BA from the George Washington University and his MA from the Johns Hopkins University’s School of Advanced International Studies.
Crowell & Moring
Nicole Sayegh Succar is a Counsel with Crowell & Moring LLP focused on economic sanctions and anti-money laundering legal, risk management and compliance advisory and investigations counseling services. She was previously the U.S. Head of HSBC North America Holdings, Inc.'s Sanctions Advisory Team, and during her time with HSBC also held interim roles as the Asia Regional Head of Sanctions and LATAM Head of Sanctions, respectively. Prior to that Nicole was a Sanctions Officer with The U.S. Treasury Department's Office of Foreign Assets Control(OFAC).
Interested in joining the task force?
We accept sanctions professionals from corporations, government agencies, international organizations, and financial institutions to serve on the ACSS Government Relations Taskforce. The scope of this volunteer activity is approximately 12 months, and term of service is for 1 year, potentially renewable. The time commitment is manageable and spread throughout the year. We plan to have quarterly conference calls of 90 minutes.
Interested candidates should email us at email@example.com along with a biography, exemplifying applicable qualifications.
Task Force Qualifications
- Required: Currently a member of ACSS.
- Have 5+ years of experience in managing an area of OFAC/sanctions topics
- Have worked for a government agency on OFAC/sanctions topics
- Is well connected in the OFAC/sanctions community to help make new connections
- Is a supporter of ACSS educational programming (or sends staff)
Due to a limited number of open task force slots, there is no guarantee of acceptance. However, applicants may also be considered for other ACSS taskforces where openings exist. If you are selected, you will be sent a formal invitation to service along with more detailed roles and responsibilities for you to evaluate before accepting or declining the invitation.