SVEN STUMBAUER Managing Director
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1 Managing Director Practice Lead Miami and Latin America Veris Consulting Inc. Suite Brickell Avenue Miami, FL Tel Cell Professional Associations Florida International Bankers Association (FIBA) South Florida Banking Institute Association of Certified Anti- Money Laundering Specialists Association of Certified Fraud Examiners Professional Risk Managers International Association German American Chamber of Commerce Languages English - Fluent Czech - Fluent Slovak - Fluent German Fluent Russian - Conversant Spanish - Conversant Education, Licenses & Certifications Master of Business Administration with concentration in Finance and International Business, Georgia Institute of Technology Graduate Certificate in International Business, Georgia Institute of Technology Bachelor of Science in International Trade, Georgia Southern University Wirtschaftsuniversität Wien (Vienna University of Economics and Business Administration) - Commerce Höhere Technische Bundeslehranstalt für Maschinenbau Wien X (Higher Technical Institution for Mechanical Engineering Vienna X) - Mechanical Engineering Completed NYSE/NASD Series 7 examination Certified Anti-Money Laundering Specialist (CAMS) Certified Anti-Money Laundering Professional (AMLP) Background Sven is a managing director with Veris Consulting and leads the Regulatory Compliance practice, as well as the Miami office and client service delivery in Latin America Sven s industry experience includes domestic and international banks, broker/dealers, insurance companies, trust companies, and hedge funds, focusing on regulatory compliance, fraud issues, Anti-Money Laundering aundering (AML) and Office of Foreign Assets (OFAC) compliance. Sven has developed a highly select client base of major financial institutions throughout the world. He has a wealth of experience leading complex, high profile global projects, providing advisory services to clients in the United States, Latin America, the Caribbean islands, Europe, Russia and Asia. In particular, he has led major engagements involving Anti-Money Laundering compliance, fraud and corruption investigations, transactional due diligence and compliance training to both financial institutions and regulators throughout the world. Sven has also provided expert guidance to leading financial institutions and their boards of directors on compliance with the Bank Secrecy Act, the U.S.A. Patriot Act, OFAC regulations, Foreign Account Tax Compliance Act and the Foreign Corrupt Practices Act. Sven works on a wide array of issues pertaining to investigation and integrity advisory services for his clients. He has extensive hands-on experience in assisting clients in providing advisory services around government matters involving Deferred Prosecution Agreements (DPAs), cease and desist orders (C&Ds) and Memoranda of Understanding (MOUs). He has developed and led numerous presentations and/ or provided reports to various government agencies such as DOJ, SEC, FINRA, Federal Reserve, OCC, OTS and FDIC. Sven specializes in AML, financial fraud, due diligence, FCPA and fraud/integrity risk management. Sven has frequently published in well known publications such as: Complinet, ACAMS, Securities Industry News and The Deal. In addition Sven has been invited to speak at several conferences in the U.S., Europe, Caribbean Islands, Latin America, and the Middle East, as well as provided briefings to a variety of U.S. and Latin American regulatory bodies on emerging issues pertaining to financial crime. He has been serving on the Board of Directors of the Florida International Bankers Association (FIBA), and co-chair of the FIBA Broker/Dealer Committee, since Prior to joining Veris, Sven served as a Compliance Examiner in the Atlanta office of the National Association of Securities Dealers (now FINRA). Most recently, he was a Director in the Risk Consulting practice of KPMG LLP. Professional and Industry Experience Sven has substantial experience leading and coordinating Forensic advisory engagements in the financial services industry. He has served as leader for planning, execution, and delivery of investigations, bribery and corruption (FCPA) due diligence and AML gap assessments, independent assessments of financial institutions AML programs, validation of transaction monitoring systems and fraud investigations in the United States, throughout Europe and Russia, the Caribbean Islands, Latin America, and Asia. He has also provided subject matter knowledge and guidance to leading financial institutions on controls to
2 comply with the Bank Secrecy Act and the USA PATRIOT Act. General Risk Consulting Experience Assisted the largest Venezuelan-based broker/dealer in conducting a review of its bond trading activity (Permutas) for potential indicators of bribery and money laundering. Led an engagement to provide Forensic investigative services through a premier U.S. law firm, focusing on the review of transactional activity that occurred in the account of an institutional Colombian customer held an international broker/dealer, as well as the investments made by this customer in various hedge funds located in the Cayman Islands and controlled by the broker/dealer. The focus of the investigation was bribery and money laundering. Led a review of transactional activity for an international broker/dealer, under the direction of a premier U.S. law firm, to identify potential indicators of money laundering and bribery, focusing on transactions originating in Venezuela. Merger & Acquisition Due Diligence Led and conducted numerous due diligence assessments of banks and broker/dealers, as well as non-financial companies in the United States and Latin America focusing on overall FCPA, regulatory, fraud, and money laundering exposure the potential acquisition presents for the acquiring entity. Transaction Monitoring Systems (AML and Fraud) Assisted several Latin American and global financial institutions in the development or enhancement of their automated monitoring solutions in several countries, including Argentina, Chile, Colombia, Ecuador, Guatemala, Honduras, Mexico, Panama, Paraguay, Peru, Venezuela and Uruguay. Assisted a Japanese based, non-bank financial institution with the enhancement of its current automated monitoring systems as part of an overall effort to enhance its AML compliance program. Assisted one of the top 5 banks in Central America with the design and subsequent implementation of its automated monitoring system across all lines of business in 4 countries within the region. Assisted several large U.S. financial institutions in deploying, implementing and independently validating commercially available fraud detection and prevention systems. Assisted several large U.S. financial institutions in deploying, implementing and independently validating commercially available AML transaction monitoring solutions, Fortent (Searchspace), Mantas, Actimize, NetEconomy, GIFTS, Prime, Norkom, ASSIST, BSA Reporter, Monitor Plus, as well as internally developed AML transaction monitoring solutions. Assisted several U.S. and foreign financial institutions in tuning and increasing the efficiency of their AML transaction monitoring solutions including, but not limited to, Fortent (Searchspace), Mantas, GIFTS, Actimize, and Prime. Conducted a validation of the transaction monitoring system for a Pakistaniheadquartered bank to assist the bank in compliance with regulatory mandates and
3 expectations. AML Transaction Lookbacks Conducted and managed transaction look-backs for several domestic and international financial institutions. Co-led a team of U.S. and Russian KPMG professionals in providing AML advisory services to a Russian Federation financial institution. KPMG assisted the bank with preparing risk assessments for customer transactions that would allow the bank to risk rank each customer as low or high risk. KPMG also assisted the bank in developing a Know Your Customer ( KYC ) checklist and a checklist for the manual transactional documentation review of particular customer transactions. The risk assessments and checklists adhered to Russian and Japanese regulatory requirements. KPMG also reviewed the bank s AML policies and procedures with regard to Russian and Japanese legislation requirements. Assisted the subsidiary of a large international financial institution in conducting a transaction look-back of its Trust business mandated by the OCC. Conducted a look-back of approximately 5.5 billion transactions of a premier U.S. financial institution for compliance with Bank Secrecy Act and relevant AML rules and regulations mandated by the Federal Reserve. FINRA/SEC Financial and Compliance Services Assisted several leading U.S. law firms in assisting their clients with regulatory and/or examination matters brought forth by FINRA, the SEC or various state regulatory agencies. The clients included broker/dealers, registered investment advisers, mutual funds, and hedge funds. The range of matters covered in this area includes, but is not limited to, the following regulatory areas: net capital, suitability, stock fraud, stock manipulation, sales practices, suitability, OFAC and AML rules and regulations, FCPA, and corporate governance issues. Previous Experience Regulatory NASD Led, coordinated, and implemented compliance exams for NASD/NYSE member firms reviewing every regulatory aspect of broker/dealers under NASD and SEC rules and regulations, including sales practices and securities related issues. Reviewed and analyzed monthly/quarterly financials of broker/dealers, and acted as a liaison for 30+ broker/dealers and the NASD. Served as a source of interpretive guidance for senior management of broker/dealers with respect to new rules and regulations of the MSRB, NASD, and SEC. Analyzed and audited broker/dealer security offerings, policies, and terms. Specialized in AML/USA Patriot Act compliance audits and financial audits. Led and participated in on-the-record testimonies of broker/dealers before the NASD.
4 Selected Publications The Global Cost of Anti-Money Laundering Compliance - Veris Consulting, USA, July 2013 Global Anti-Bribery and Corruption Compliance The FIRMA Forum, Issue 1, 2013, USA, April 2013 Broker/Dealers Legal Requirements and Best Practices Combined Antimoneylaundering.us, Venezuela, November 2009 Anti-Money Laundering Detection Systems Antimoneylaundering.us, Venezuela, July 2009 The future of international private banking in the US: how to maintain compliance and profitability Complinet, USA, March 2009 Los agentes de bolsa y la nueva fase de cumplimiento anti-lavado de dinero Legalmente Hablando, Venezuela, November 2008 Money Services Businesses Friend or Foe? Antimoneylaundering.us, Venezuela, July 2008 Broker/Dealer AML Compliance Enters News Phase Antimoneylaundering.us, Venezuela, July 2008 The Future of International Private Banking in the United States Florida International Bankers Association Newsletter, USA, July 2008 Money Services Businesses Friend or Foe? Florida International Bankers Association Newsletter, USA, June 2008 MSBs Friend or Foe? Securities Industry News, USA, April 2008 Global Anti-Money Laundering Compliance ACAMS Today, USA March 2008 AML Considerations in the Context of Mergers and Acquisitions Complinet, November 2007 The Rinse Cycle Anti-Money Laundering Considerations in M&A Deals The Deal, October 2007 AML Compliance Poses New Challenges for Broker/Dealers Complinet, August 2007 Broker-Dealer AML Compliance New Challenges Securities Industry News, USA, August 2007 Selected Speaking Engagements Trends in Compliance Risk: Anti-Money Laundering and Foreign Asset Control Requirements - Hispanic National Bar Association 2013 Annual Convention, USA, September 2013 The Cost of Regulatory Enforcement Actions for Global Financial Institutions - XVII Congreso Hemisférico Para la Prevención de Lavado de Dinero y el Combate de Financiamiento del Terrorismo, Panama, August 2013 The Global Cost of AML Compliance Challenges and Opportunities for Financial Institutions Globally - XIII Congreso Panamericano de Riesgos de Lavado de Activos y Financiación del Terrorismo, Colombia, July 2013
5 FATCA Challenges and Opportunities for International Financial Institutions Inaugural FATCA Seminar, Jamaica, May 2013 Anti-Money Laundering Compliance - New challenges and pitfalls encountered by financial institutions globally - 7th Annual Fraud and Forensic Accounting Education Conference, USA, May 2013 Broker Dealer & Wealth Management - Beneficial Ownership, FATCA, Insider Trading and more. What s on the brokerage and wealth management industry s AML radar? Florida International Bankers Association, 13th Annual AML Compliance Conference, USA, February 2013 OFAC Challenges - What s new in the OFAC Landscape and what might be coming in 2013? Florida International Bankers Association, 13th Annual AML Compliance Conference, USA, February 2013 FATCA Challenges and Opportunities for International Financial Institutions - VIII Fórum de Prevenção a Crimes Econômicos, Rio de Janeiro, November 2012 AML Issues in Emerging Technology: Pre-paid cards, mobile payments, remote cheque deposits" Inaugural Anti-Money Laundering/Counter-Financing of Terrorism Conference, Jamaica, October 2012 Managing Possible Hits: Real Time Scanning of Wire Transfers, Sanctioned/Country Embargos, Watch Lists Inaugural Anti-Money Laundering/Counter-Financing of Terrorism Conference, Jamaica, October 2012 Challenges in Detecting Money Laundering and Complying with International Sanctions - 2º Congresso de Combate e Prevenção à Lavagem de Dinheiro e ao Financiamento do Terrorismo, Sao Paulo, Brazil, September 2012 FATCA Challenges and Opportunities for International Financial Institutions - Seminario de Prevencion de Lavado de Activos, Argentina, August 2012 The Role of the Board of Directors in AML Compliance - XII Congreso Hemisférico Para la Prevencion de Lavado de Dinero y el Combate de Financiamiento del Terrorismo, Panama City, Panama, August 2012 OFAC and CISADA New Challenges for International Banks - PLA 2012, Lima, Peru, May 2012 Foreign Account Tax Compliance Act (FATCA) What you should do right now - - PLA 2012, Lima, Peru, May 2012 Emerging Trends in Anti-Money Laundering and Sanction Compliance in Latin America. Chilean Banker s Association, Chile, March 2012 AML Risks in Mergers & Acquisitions - Does Acquiring a Troubled Institution Lead to Other AML Risks? Florida International Bankers Association, 12th Annual AML Compliance Conference, USA, February 2012 Broker Dealers New Challenges in the U.S. Regulatory Environment - Fiduciary Standards, Foreign Finders, FATCA, and More. Master / Sub Accounts, Micro-Cap Fraud, Insider Trading Are They on Your Radar? Florida International Bankers Association, 12th Annual AML Compliance Conference, USA, February 2012 Current Trends in Anti-Money Laundering Peruvian Central Bank, Peru, December 2011 Know Your Customer Trends and Challenges for Financial Institutions Operating in
6 Latin America. Association of Peruvian Banks, Peru, December 2011 Emerging Trends in Anti-Money Laundering and Sanction Compliance in Latin America. Congreso Mundial sobre Prevención de Lavado de Activos y Financiamiento al Terrorismo (CIPLAD), Costa Rica, August 2011 Rethinking the Mirage of Underperforming or Outperforming Businesses Risk Management Reconstructed Caribbean Association of Audit Committee Members, Trinidad and Tobago, July 2011 Broker Dealers Issues - Hot Topics, Best Practices, Red Flags, and Recent Developments in the Broker Dealer Space Florida International Bankers Association, 11 th Annual AML Compliance Conference, USA, February 2011 Venezuelan Currency Restrictions and their impact on U.S. Broker/Dealers and Internationally Operating Banks Florida International Bankers Association, 11 th Annual AML Compliance Conference, USA, February 2011 Co-Chair of4th Annual Anti-Money laundering conference organized by the Banker s Association for Central and Eastern Europe (BACEE), Hungary, November 2010 Risk and Control Issues for Financial Institutions Caribbean Association of Audit Committee Members, St. Kitts, October 2010 Using Technology to Drive Value by Managing Risk and Improving Performance Caribbean Association of Audit Committee Members, St. Kitts, October 2010 International Best Practices in Anti-Money Laundering Compliance and Expectations of U.S. Correspondent Banks Central Bank of Uruguay, Uruguay, May 2010 FCPA and the Bank s Responsibilities Florida International Bankers Association, USA, April 2010 The evolving landscape of Broker/Dealer AML compliance Florida International Bankers Association, 10 th Annual AML Compliance Conference, USA, February 2010 FCPA from the Bank s perspective Florida International Bankers Association, 10 th Annual AML Compliance Conference, USA, February 2010 Co-Chair of 3 rd Annual Anti-Money laundering conference organized by the Banker s Association for Central and Eastern Europe (BACEE), Hungary, November 2009 Temas candentes relativos al lavado de dinero en la agenda de los bancos Estadounidenses: Las Permutas Venezolanas y las casas de cambio Mexicanas 11th International Seminar of Money Laundering and Terrorist Financing Prevention, Mexico, October 2009 Creating a Pathway to Yes! Overcoming obstacles to satisfying a bank s EDD requirements for MSBs and foreign financial institutions, 4 th International Money Transmitter Convention, USA, October 2009 Current Regulatory Enforcement Trends for Broker/Dealers Florida International Bankers Association, USA, September 2009 Anti-Money Laundering Compliance for International Broker/Dealers Current Trends and Leading Practices the case of Venezuelan Permutas, V. Conferencia Internacional Antilegitimación de Capitales y Contra el Financiamiento al Terrorismo, Venezuela, July 2009 The Increase in Fraud in Light of the Current Financial Crisis Florida International Bankers Association, USA, May 2009
7 A Look at Global Risk Management in 2009 KPMG s Risk Management in Banking Survey Florida International Bankers Association, USA, February 2009 Sampling Techniques and Compliance Testing. National Society of Compliance Professionals, USA, February 2009 Applying BSA/AML Risk Assessments throughout the enterprise and in your IT surveillance systems, Florida International Bankers Association, 9 th Annual AML Compliance Conference, USA, February 2009 The Role of Forensic Investigators in Assisting Financial Institutions to Prevent Money Laundering, Congreso Mundial sobre Prevención de Lavado de Activos y Financiamiento al Terrorismo (CIPLAD), Costa Rica, November 2008 AML Compliance Challenges with Cross-Border Operations, Mexican Banker s Association, 10th International Seminar of Money Laundering and Terrorist Financing Prevention, Mexico, October 2008 Fundamental Elements of an AML Compliance Program, Mexican Banker s Association, 10th International Seminar of Money Laundering and Terrorist Financing Prevention, Mexico, October 2008 Fraud Risk Management for Financial Institutions, Cayman Islands Bankers' Association, Grand Cayman, October 2008 Know Your Customer From the Bank s Point of View. How to Maintain Accounts for MSBs and Casas de Cambio, 3 rd International Money Transmitter Convention, USA, September 2008 Anti-Money Laundering Compliance for Broker/Dealers New Challenges, XII Congreso Hemisférico Para la Prevencion de Lavado de Dinero y el Combate de Financiamiento del Terrorismo, Panama, August 2008 The Future of International Private Banking: Current Regulatory Trends and Best Practices, Florida International Bankers Association, USA, July 2008 Anti-Money Laundering Compliance for International Broker/Dealers - Current Trends and Leading Practices, IV. Conferencia Internacional Antilegitimación de Capitales y Contra el Financiamiento al Terrorismo, Venezuela, July 2008 Anti-Money Laundering Considerations for Hedge Funds and Fund Administrators, Cayman Islands Bankers' Association, Grand Cayman, April 2008 International Correspondent Banking Current Trends and Leading Practices, 6th Offshore Alert Financial Due Diligence Conference, USA, April 2008 Anti-Money Laundering Considerations for Trust and Investment Management, The Fiduciary & Investment Risk Management Association, USA, March 2008 Anti-Money Laundering Compliance for Broker/Dealers Current Trends and Leading Practices, Florida International Bankers Association, USA, March 2008 AML Transaction Monitoring Systems Leading Practices and Common Pitfalls, Florida International Bankers Association, 8 th Annual AML Compliance Conference, USA, February 2008 Money Laundering Red Flags, Typologies, System Challenges, U.S. Middle East/North Africa Treasury Private Sector Dialoque on Combating Money Laundering and Terrorist Financing, Dubai, December 2007 Sanction Compliance for Global Financial Institutions, Middle East-North Africa
8 International Money Laundering/Terrorist Financing Conference & Exhibition, Dubai, December 2007 AML Transaction Monitoring Systems How to Successfully Deploy an Automated AML Monitoring System, Middle East-North Africa International Money Laundering/Terrorist Financing Conference & Exhibition, Dubai, December 2007 Fraud Risk Management How Banks Are Facing Up to the Challenge, South Florida Banking Institute, October 2007 Global Anti-Money Laundering Survey 2007 How banks are facing up to the challenge, 3 rd Annual AML Compliance Conference, Grand Cayman, October 2007 Global Anti-Money Laundering Survey 2007 How banks are facing up to the challenge, Florida International Bankers Association, USA, September 2007 AML Transaction Monitoring Systems Leading Practices and Common Pitfalls, Webinar, Florida International Bankers Association, USA, September 2007 AML Transaction Lookbacks Leading Practices, American Bankers Association Regulatory Compliance Conference, USA, June 2007 Managing AML Risks Involving Broker/Dealers and Mutual & Hedge Funds, Webcast, Association of Certified Anti-Money Laundering Specialists (ACAMS), USA, October 2006 AML Transaction Monitoring Systems and Transaction Lookbacks Leading Practices, ABA/ABA Money Laundering Enforcement Conference, USA, October 2006
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