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Ethics and Risk for OFAC: Two Aspects of One Compliance Reality
LIVE Webcast
Gerard (Jerry) W. LiVigni
Senior Compliance Officer, Office of Foreign Assets Control (OFAC)
U.S. Department of the Treasury
Mr. LiVigni has over 28 years of International Banking Operations, Anti-Money Laundering, and Bank Secrecy Act compliance experience. Before joining OFAC Jerry had been Vice President and Compliance AML Training Officer for BNP Paribas’s Bank and Securities affiliate offices in the United States. He was responsible for USA PATRIOT Act, AML policies and procedures, as well as monitoring BSA and OFAC examination work programs.
Mr. LiVigni is a key member of the Compliance Outreach and Implementation team at the Treasury Department’s Office of Foreign Assets Control (OFAC) and plays a front line role in the financial war against international terrorists, narcotics traffickers, and the addressing of OFAC sanction program regulations. He provides practical advice on a daily basis to institutions, firms, and individuals from around the world on OFAC issues, routinely interacting with his regulatory and private industry colleagues.
Mr. LiVigni has been an often requested speaker at conferences both here an abroad by regulatory, law enforcement, and private industry peers who are “concerned good actors” and are keen on having OFAC issues made clear by appealing to one’s interest and common sense. He has addressed Banks and Credit Unions; Broker-Dealers and other Security Industry Professionals; Casinos; Charities; Examiners and Regulators; MSBs; Payroll Professionals; and “other concerned individuals.” Jerry believes that the hallmark of addressing OFAC concerns either as a financial institution or a “person” who comes under OFAC jurisdiction, one ought to rely on an "ethical and reasonable approach” in one’s risk appraisal and its application.
Daniel L. Tannebaum (CFE)
OFAC Compliance Manager
Federal Reserve Bank of New York
Daniel Tannebaum, CFE is the OFAC Compliance Manager for the Federal Reserve Bank of New York. Dan currently oversees the Office of Foreign Assets Control (OFAC) program for the FRBNY’s International Treasury Services group and provides guidance and clarification on OFAC matters to other business lines of the Bank.
Dan previously was a Senior Consultant at Protiviti Inc., serving in the Regulatory Risk Practice. He managed the OFAC sub-practice as Protiviti’s OFAC subject matter expert. Dan has conducted BSA/AML/OFAC compliance audits for major domestic and international financial institutions and developed OFAC policies, procedures and risk assessments for various clients. He has advised clients on the selection and implementation of transaction monitoring systems and developed and delivered targeted OFAC and AML training.
Prior to joining Protiviti, Dan served as a Compliance Officer with OFAC, US Department of the Treasury. While serving at OFAC, his areas of expertise included guidance and clarification for the financial services industry, terrorist fund diversion in the charitable sector, gaming regulations with a focus on tribal gaming and export/import regulations.
Dan published several articles in trade magazines and worked with senior Treasury officials to publish the “OFAC Risk Matrix for the Charitable Sector.” He has spoken to various governmental and industry-specific groups. Dan has spoken extensively to the commercial and tribal gaming communities and was the keynote speaker at the Office of the Commissioner of Financial Institutions of Puerto Rico’s (OCFI) First Annual Casino Management Seminar. He was appointed in 2006 to the Indian Gaming Working Group, an interagency task force comprised of various federal law enforcement agencies providing advisement to the tribal gaming community. In this role Dan spoke to the tribal gaming sector through the coordination of the FBI’s Indian Country Unit and the Department of the Interior’s National Indian Gaming Commission. Dan received the FBI Director’s Certificate for Exceptional Service in the Public Interest in May 2007. He was an instructor at the Department of Homeland Security’s Federal Law Enforcement Training Center course on International Banking and Money Laundering, and has trained Federal Reserve national supervisory examiners and FDIC examiners on OFAC regulations and policies.
Prior to joining OFAC, Dan was a lobbyist for several large international corporations and domestic historical preservation organizations and served as assistant to Reps. Rosa DeLauro and Joseph Hoeffel in the US House of Representatives. Dan holds a B.A. in Political Science from the George Washington University and is a Certified Fraud Examiner.
Darren Donovan
Principal, Forensic Services
KPMG LLP
Darren Donovan is the National Banking and Finance Industry Leader of KPMG LLP’s U.S. Forensic Advisory Services practice. He works on a wide array of issues pertaining to investigation and integrity advisory services for his clients, which include leading national and multinational financial institutions, as well as public service and not-for-profit organizations.
Mr. Donovan has extensive hands-on experience in the areas of anti-money laundering, financial fraud, due diligence, FCPA, and fraud/integrity risk management. Mr. Donovan has worked for a highly diverse client base throughout the U.S. and the world. In 2004, he personally conducted in-country projects in China, Korea, Japan, Australia, and Brazil.
Darren’s clients have included leading Regional, U.S., International and Multinational-based Investment Firms, Broker-Dealers, Banks and Non-Bank Financial Institutions; Leading Organizations Under Government Order.
Darren’s engagement work has included development, remediation, assessments, independent testing and validation of programs related to Bank Secrecy Act/Anti-Money Laundering, Anti-Terrorist Financing, including projects targeting policies and procedures, training, and transaction monitoring; transaction look backs; PEP/OFAC investigations and FCPA compliance.
Daniel B. Pickard
Partner
Wiley Rein LLP
Daniel B. Pickard’s practice encompasses the laws and regulations governing international trade and business transactions, with particular emphasis on import remedy, economic sanctions, and export controls issues. Mr. Pickard represents and advises clients in matters related to trade remedy investigations, export controls, antiboycott measures, the Foreign Corrupt Practices Act (FCPA), the Foreign Agents Registration Act (FARA), and economic sanctions regulations administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC).
Mr. Pickard’s experience includes developing global corporate compliance programs; conducting internal investigations relating to potential violations; and appearing before the relevant agencies in connection with investigations, licensing and enforcement actions. Mr. Pickard represents clients in front of the U.S. International Trade Commission, OFAC, the U.S. Department of Justice, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) and International Trade Administration (ITA), and the U.S. Department of Defense's Defense Security Service (DSS).
Ethics and Risk for OFAC
LIVE Webcast
Speaker Firms And Agencies:
U.S. Department of the Treasury
Federal Reserve Bank of New York
Upcoming events.