Advisory Board

Clay Stevenson

Advisory Board Chair Managing Director | Head of Sanctions & Embargoes, Americas
Deutsche Bank - USA 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.

Matt BellSenior Managing Director - Practice Leader of Export Controls & Sanctions
Forensic & Litigation Consulting Matt Bell is a Senior Managing Director and the Leader of the Export Controls & Sanctions offering in the Forensic & Litigation Consulting (FLC) segment at FTI Consulting, and he is based in Houston. He specializes in international trade compliance including export controls, economic sanctions, antiboycott, and related US and global regulations.

Mr. Bell helps his clients build or enhance their trade compliance programs through procedural enhancements, audits, and trainings that are properly benchmarked to leading practices.Mr. Bell also has experience overseeing large and highly complex global investigations in some of the most challenging regions of the world. His specialization is honed through his experience as a senior in-house counsel for several organizations that committed significant resources to designing and implementing world-class trade compliance programs. As a result, he advises his clients from a unique perspective that balances compliance with these highly complex laws and regulations with the practical realities of implementing his advice in the day-to-day operations of the company.

Mr. Bell has extensive experience advising clients on the complex regulations related to encryption controls, de miminis analyses, second incorporation rule application, and sanctions regulations, especially as they apply to avoiding business in sanctioned jurisdictions or with sanctioned parties, as well as in wind-down of operations in sanctioned jurisdictions. His expertise spans across several industries including energy, telecommunications, technology, and aerospace/defense, as well as for both US and non-US companies with extensive global operations.

Mr. Bell has made his career building best-in-class compliance programs under intense government scrutiny including extensive experience working with the US Departments of Justice, Commerce, and Treasury as part of government investigations, civil and criminal settlements, and helping companies through the rigors of government-mandated audits and monitorships. Mr. Bell also advises on compliance with the export control regulations administered by the Nuclear Regulatory Commission, Department of Energy, and Department of State.

Prior to FTI Consulting, Mr. Bell held senior legal and compliance positions in major multi-national companies in the telecommunications and energy industries, including having served as a chief compliance officer, senior global anticorruption counsel, global trade compliance counsel, and regional compliance counsel for these organizations. Much of his work with these companies occurred during investigations related to and as a result of record-setting settlements with various US government agencies related to FCPA, export controls, and sanctions violations. Mr. Bell started his career in consulting with international trade practices in two of the Big 4 consultancies.

Mr. Bell is an active member in the American Bar Association, Section of International Law and serves on advisory committees for both Trace International and the Association of Certified Sanctions Specialists.

Brian Grant Global Head of Sanctions Compliance
Mitsubishi UFJ Financial Group (MUFG) Brian Grant is the Global Head of Sanctions Compliance for the Mitsubishi UFJ Financial Group (MUFG), one of the world's largest and most diversified financial groups, with responsibility for sanctions risk management and internal controls across the global enterprise. Mr. Grant’s other industry experience includes heading Citigroup’s OFAC Compliance and Enterprise Risk function and serving as a leader in Ernst & Young’s AML practice area. Prior to joining industry, he held a number of positions in the US Department of the Treasury, including as a Compliance Officer in the Office of Foreign Assets Control; a Financial Attaché in the Middle East region and, most recently, as Director of the Office of Global Affairs and member of the Senior Executive Service. He holds Bachelor’s and Master’s degrees from Georgetown University’s School of Foreign Service.

Francisco Rapp Chief Compliance Officer, Sanctions and Anti-Bribery
Citi Mr. Rapp heads Citi’s Sanctions and Anti-Bribery Compliance programs. In this role, he manages a global team of subject matter experts responsible for the design and implementation of Sanctions and Anti-bribery enterprise-wide compliance risk-management frameworks. He also provides specialized advice and support to Citi businesses with guidance on compliance issues in the 100+ countries in which the firm operates. Mr. Rapp is responsible for the design and oversight of Citi’s Sanctions and Anti-Bribery Policies and Standards. In addition, he is Citi’s liaison with the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), and a member of the advisory board of the Association of Certified Sanctions Specialists (ACSS). He has been with Citi for over 20 years, serving in various Internal Audit, Risk Management and Compliance roles at country, regional and corporate levels. Before joining Citi, he held positions as financial controller, audit manager and other senior advisory roles in international companies. Mr. Rapp holds a CPA degree from the Universidad de Buenos Aires (UBA) and holds an Master in Finance from the Centro de Estudios Macroeconomicos (CEMA) of Buenos Aires, Argentina.

Jacqueline SantosSenior Vice President Enterprise Compliance
Bank Secrecy/Anti-Money Laundering and Sanctions
PNC Bank Ms. Santos is responsible for Global Sanctions and AML Regulatory control programs at PNC Bank. As Senior Vice President and Enterprise Sanctions Officer, she is responsible for managing the compliance teams that support Sanctions Compliance. She has AML compliance oversight for Trade Finance, PNC Foreign Offices and AML Special Programs. Ms. Santos’ over 30 years’ experience with PNC Bank has involved a number of compliance leadership positions in support of the Corporate and Institutional Bank, Treasury Management and Bank Operations including direct management of Funds Transfer Operations and Large Currency Reporting. She has coordinated and lead integration activities for several mergers and acquisitions specific to Sanctions and Anti-Money Laundering compliance programs. Ms. Santos has a Bachelor of Science Degree from Kean University and is a current member of the Women’s Business Resource Group.

Todd Willis Global Trade Advisor
Caterpillar, Inc. Following a military and federal service career of over 25 years, Mr. Willis accepted the newly established role of Global Trade Advisor at Caterpillar, Inc. In this role, he is responsible for supporting the strategic development, delivery and execution of international trade to support the enterprise. In addition, Mr. Willis works to enhance and manage relationships with U.S. and foreign government law enforcement and regulatory agencies.

Prior to his current position at Caterpillar, Mr. Willis was the Deputy Director at the Export Enforcement Coordination Center (E2C2) and Senior Policy Advisor within the Office of the Assistant Secretary for Export Administration, where he developed and promoted efficient export control policies. Prior assignments include Director of the Munitions Control Division within the Office of Strategic Industries and Economic Security at the Bureau of Industry and Security (BIS). As the first Division Director for MCD he served as the senior advisor on dual-use and munitions technology issues within Department of Commerce and coordinated the review of export control issues among relevant USG organizations. Further, working within the Defense Department, Mr. Willis was the Division Chief for the Dual-Use Licensing Division within the Defense Technology Security Administration (DTSA).

Mr. Willis has a Master’s of Science degree in National Security from NDU, Eisenhower School. He also graduated cum laude with an MBA from California State University, Hayward and has a B.A.in Political Economics from the University of the Pacific.