Tracy Angulo is an accomplished attorney, consultant, Certified Fraud Examiner (“CFE”) and Certified Anti-Money Laundering (“AML”) Specialist, with more than 20 years of expertise in administrative law and investigations, the last 11 of which she specialized in securities and banking law and regulation, Bank Secrecy Act (“BSA”), AML and sanctions compliance, and financial fraud investigations.
Tracy provides a wide compilation of BSA / AML / Sanctions / Office of Foreign Asset Control (“OFAC”) compliance services to all manner of financial institutions under regulatory scrutiny or examinations (consent orders, Matters Requiring Immediate Attention (“MRIAs”) and Matters Requiring Attention (“MRAs”), and monitorships) including: comprehensive risk assessments (geography, customer, product); testing and validation of controls and procedures implemented by a financial institution in response to its monitor’s recommendation and consultation; advice and counsel on BSA/AML/OFAC and Global sanctions / watchlist compliance issues; gap analyses; AML independent tests; AML Program reviews and assessments; management of a Financial Intelligence Units and transaction monitoring look-backs; BSA/AML/Sanctions Compliance training; assessments of Customer Identification Programs, Know Your Customer (“KYC”), and Due Diligence Programs; risk coverage and efficacy assessments of transaction monitoring surveillance systems, and the assessments of the governance of said systems; development of AML financial fraud detection scenarios tailored to the risks of the financial institution; and BSA/AML/Sanctions Program remediation, including the drafting and development of new policies, procedures, and processes.
Engaged by domestic and global financial institutions to assist in the remediation and enhancement of Global Sanctions policies and procedures to protect the institution from sanctions risk including but not limited to: rewriting of policies and procedures; conducting Sanctions risk assessments; assisting with the User Acceptance Testing (“UAT”) of new sanctions filters; reviewing and remediating Good Guy rules and internal watch lists; and establishing list governance processes and procedures. Assists with the implementation and tuning of sanctions and watch list screening systems and AML Compliance transaction monitoring systems.
Engaged by a Fortune 100 company for BSA/AML related services pertaining to a transaction look-back and lead a team of eight analysts and researchers to investigate and clear over 500 outstanding transaction alerts.
Seconded as the Acting Head of the Financial Intelligence Unit for a large global financial institution, leading team of 15 to: review and disposition over 1,200 AML-related transaction alerts, conduct quality assurance reviews on over 3,800 alert dispositions, and conduct investigations into 60 more than cases.
Engaged by a large global broker-dealer to assess the BSA/AML risk to the organization and develop transaction monitoring scenarios to detect and mitigate the institution’s risks.
Engaged by a large global bank/broker-dealer’s Internal Audit Department to assess the fortitude of the institution’s Anti-Financial Crime Program.
Engaged by a foreign branch of a large global bank to assess and remediate the bank’s BSA/AML/Sanctions program, leading the workstreams to remediate the bank’s KYC Program, Training Program, and Sanctions program.
Recipient of multiple Quarterly Employee Recognition awards, awards for appreciation of “Outstanding Contributions” made in client engagements, time-off awards, and other “Extra Effort” bonuses/awards.
J.D., Columbus School of Law, Catholic University of America B.A., Sociology, University of Maryland, College Park
Maryland State Bar (1997) United States District Court for the Eastern and Western Districts of Maryland (1998) District of Columbia State Bar (2004) Certified Fraud Examiner (2013) Certified Anti-Money Laundering Specialist (2016)
Membership and Activity Information
District of Columbia Bar Association, Member D.C. Bar, Section on Corporation, Finance and Securities Law, Member American Bar Association, Member Association of Certified Fraud Examiners (ACFE), Member Association of Certified Anti-Money Laundering Specialists (CAMS), Member National Association of Professional Women (NAPW), Woman of the Year/VIP Member (2012/2013)