Faculty

Financial Integrity Institute


Our mission is to advance financial integrity globally by conducting and promoting at the highest standards research, education and professional excellence in anti-money laundering and countering the financing of terrorism, targeted sanctions, anti-corruption and international tax evasion policies and practices.

Director, Richard Gordon

Deputy Director, Juscelino F. Colares

Associate Director, Jonathan H. Adler

Associate Director, Michael Benza

Launched in the fall of 2015, our mission is to advance financial integrity globally by conducting and promoting at the highest standards research, education and professional excellence in anti-money laundering and countering the financing of terrorism, targeted sanctions, anti-corruption and international tax evasion policies and practices.

Adjunct Professors of Law and Distinguished Practitioners of Financial Integrity:

Yves Aeshlimann
Mr. Aeschlimann is Senior Vice President, Member of the Executive Committee, General Counsel, and Global Head of Compliance at Edmond de Rothschild (Suisse) SA. Previously, he was Senior Financial Sector Specialist in the Financial Market Integrity group at the World Bank. Before joining the Bank he was an elected Prosecutor, then an Investigating Magistrate attached to Geneva's Criminal Court, Financial Section, where he was in charge of criminal investigations in complex cases, and in charge of executing Requests for Mutual Legal Assistance from foreign states. He was also a member of the Conference of the Swiss Prosecuting Authorities.
Richard Barrett
Richard Barrett CMG OBE is a Senior Vice President at The Soufan Group, a security consultancy based in New York. He is also a Fellow at the New America Foundation in Washington, the Royal United Services Institute in London, and the Centre for Research and Security Studies in Islamabad. He is a board member and strategic advisor for various institutions including the International Centre for Counter Terrorism – The Hague, the Global Center on Cooperative Security in Washington, the Oxford Research Group in the UK, and Projects for the 21st Century in London and Washington. He also serves on the Independent Review Panel of the Global Community Engagement and Resilience Fund in Geneva. From March 2004 to December 2012 he was Coordinator of the Al-Qaida and Taliban Monitoring Team at the United Nations in New York and in 2005 he helped establish what became the United Nations Counter Terrorism Implementation Task Force following adoption by the General Assembly of the Global Strategy to Counter Terrorism in 2006. Before joining the United Nations, he worked for the British Government both at home and overseas with postings in Canada, Jordan, Turkey and the United States.
Jean Pierre Brun
Mr. Brun is Senior Financial Sector Specialist, The World Bank. He worked as a Prosecutor and Investigative Judge in France for 12 years. He prosecuted and investigated corruption, fraud, illegal financing of political campaigns, money laundering and organized crime, and worked as an auditor both in the public and the private sector. Mr. Brun was also a Director for Forensic and Fraud investigations at Deloitte Finance in Paris. He joined the World Bank in 2008 as a Financial Sector Specialist, where he works on Anti Money Laundering and Terrorist Financing, providing technical assistance and training to investigators, prosecutors and judges dealing with financial crime.
John J. Byrne, CAMS
Mr. Byrne is Executive Vice President of the Association of Certified Anti-Money Laundering Specialists. He is an internationally-recognized regulatory and legislative attorney with over 25 years of experience in financial services issues, with expertise in regulatory oversight, policy and management, anti-money laundering, privacy and consumer compliance. He was most recently president of Condor Consulting LLC and prior to that the global regulatory relations executive for Bank of America and the director of the American Bankers Association's Center for Regulatory Compliance. Mr. Byrne has received a number of awards, including the Director's Medal for Exceptional Service from the Treasury Department's Financial Crimes Enforcement Network (FinCEN) and the ABA's Distinguished Service Award for his career work in the compliance field.
J.B. Delston
Professor Delston is Assistant Teaching Professor, University of Missouri-St. Louis Department of Philosophy. She received her Ph.D. in Philosophy 2011 at the Washington University in St. Louis. Her Dissertation was entitled “A Hybrid Theory of Global Justice.” She is the author of “The Criminalization of Money Laundering and Terrorism in Global Contexts: A Hybrid Solution” in The Journal of Global Ethics. 10:3 (December 2014).
Ross Delston, CAMS
Mr.Delston is a Washington, DC - based attorney, expert witness, Certified Anti - Money Laundering Specialist (CAMS), and former banking regulator(FDIC) who has specialized in Bank Secrecy Act and AML / CFT issues for over 15 years.He has been a consultant to the IMF and World Bank on AML / CFT and banking issues for 18 years and has participated in the AML / CFT assessments of nine offshore financial centers.Representative engagements include participating in two major compliance projects involving international banking, AML / KYC, and sanctions, including OFAC; five annual independent AML audits of a publically - held MSB; and acting as an expert witness and / or litigation consultant on BSA/ AML compliance in eight civil cases in Federal and state courts, including a civil forfeiture case as an expert for the U.S.Attorney’s Office(SDNY).Delston is co - author of two law review articles on trade - based money laundering and has been quoted in numerous publications, including the Wall Street Journal, American Banker, Hindu Business Line(India), and the Nikkei(Japan).Previously, he was a Consulting Counsel, IMF, specializing in AML / CFT issues; Of Counsel, Jones Day; Assistant General Counsel, Assisted Acquisitions, FDIC; and Counsel, US Export - Import Bank.
Phil DeLuca
Mr. DeLuca is Senior Vice President and Director of Compliance Controls at U.S. Bank. Prior to joining U.S. Bank, he led the AML investigations department of a large global bank where he and his team pioneered the use of issue-based typology driven investigations. DeLuca has over 30 years of financial services investigations management experience and has conducted and managed numerous high profile/sensitive anti-money laundering/counter terrorist financing investigations. He has partnered with all levels of law enforcement to develop leading edge investigative strategies, and has been recognized by the highest levels of government for his leadership and expertise in leveraging an issue-based investigation approach to identifying data characteristics that are potentially indicative of human trafficking. Recently DeLuca was invited to present at the White House Forum to Combat Human Trafficking with a panel of colleagues from law enforcement and the technology industry. DeLuca regularly advises industry, government, and law enforcement agencies on typology development and data interrogation techniques to be more proactive and productive in detecting illicit financial activity.
The Honorable Sue Eckert
Ms. Eckert is Senior Fellow at the Watson Institute for International Affairs at Brown University, where she directs projects on UN Targeted Sanctions and Terrorist Financing, and explores cybersecurity governance issues. Her research examines issues at the intersection of security and political economy; her coedited book Targeted Sanctions: The Impacts and Effectiveness of UN Actions will be available fall 2015. She works extensively with UN bodies and the private sector to enhance instruments of collective security, organizing the 2014-15 High Level Review of UN Sanctions sponsored by five Member States; participating in the series of multilateral initiatives, including the Interlaken, Bonn-Berlin, and Stockholm Processes; and developing workshops, simulations, training, and research for the Security Council and related groups. She was appointed by President Clinton as Assistant Secretary of Commerce for Export Administration, responsible for US dual-use export control and sanctions policies. Previously, she served on the professional staff of the US House of Representative's Committee on Foreign Affairs, where she oversaw technology transfer, international trade and sanctions, and national security/nonproliferation issues.
Ari Gabinet
Mr. Gabinet is Executive Vice President and General Counsel at OppenheimerFunds. one of the oldest and largest independent investment management firms in the country. He oversees the firm’s Legal, Compliance, and Internal Audit functions, providing legal, regulatory, compliance, and control testing to all OppenheimerFunds business units. Prior to joining OppenheimerFunds, Gabinet was a principal in Vanguard’s legal department, where he was responsible for legal teams covering investment management; brokerage, distribution, transfer agency and advice; litigation, shareholder services, and data security; and tax and international matters. Previously he was head of the Philadelphia office of the Securities and Exchange Commission, responsible for the SEC’s enforcement and regulatory examination programs in Pennsylvania, Maryland, Delaware, Virginia, West Virginia, and the District of Columbia. He was a litigation partner at Dechert, LLP, and began his career at Wilkie Farr & Gallagher.
Andrea Gacki
Ms. Gacki is Acting Deputy Director, Office of Foreign Assets Control, U.S. Department of the Treasury. Previously, Andrea served as OFAC’s Assistant Director for Licensing from 2010 to 2014. Andrea first joined OFAC in March 2008 as the Senior Sanctions Advisor for Program Policy & Implementation. Prior to joining OFAC, Andrea was a trial attorney in the Federal Programs Branch of the Civil Division of the U.S. Department of Justice, where she represented OFAC by, among other things, defending against designation challenges brought by the Al-Haramain Islamic Foundation and the Islamic American Relief Agency, and where she served as a senior member of the Justice Department’s Terrorist Designation Team. Before joining the Justice Department, Andrea was an associate at the law firm of Hogan & Hartson LLP (now Hogan Lovells LLP), and she clerked for the Honorable Avern Cohn on the U.S. District Court for the Eastern District of Michigan. She is a graduate of the University of Michigan Law School and the University of Michigan-Ann Arbor.
Katharine Goepp
Ms. Goepp is Senior Policy Counsel, Asset Forfeiture and Money Laundering, Criminal Division, U.S. Department of Justice. Since 2005, Ms. Goepp has been first policy counsel and then senior policy counsel there. She has extensive experience with asset forfeiture laws on a national level in their development, their structure, and how they have been applied, as well as how the program administration works and the policy implications both domestically and internationally. She has given presentations and training on forfeiture topics for a broad range of audiences. As a member of the policy unit, she has provided direct support to Criminal Division sections on numerous money laundering topics. She continues regularly to teach a section on the criminalization of money laundering and how the Bank Secrecy Act reporting requirements fit into that structure, as well as one on emerging payment methods and how they relate money laundering. She was was responsible for developing, clearing, and providing support to educate members of Congress on the Administration’s legislative package on amendments for forfeiture and money laundering statutes, as part of the Administration’s Strategy to Address Transnational Organized Crime issued in July 2011.
Larissa Gray
Ms. Gray is Senior Financial Sector Specialist at The World Bank In the Financial Market Integrity Unit, she helps Bank client countries with using anti-money laundering tools for addressing financial crime, strengthening financial soundness and integrity, and addressing development issues, in particular stolen asset recovery. She has also co-authored four publications under the Stolen Asset Recovery Initiative on the topics of non-conviction based asset forfeiture, politically exposed persons, barriers to asset recovery, and practical handbook for practitioners.
Alek El-Kamhawy
In the United States, Alek El Kamhawy is a criminal defense attorney, representing clients in both federal and state courts, where he specializes in complex litigations including terrorism, terrorism financing, and related matters. He is also Honorary Professor of Law and Director of the American Common Law Center at the Law Faculty, Taras Shevchenko National University in Kyiv, Ukraine, where he teaches courses in the prevention of public corruption, money laundering, and terrorism financing. He is fluent in English, Arabic, and Russian, and has a master’s degree from Ohio State University and a J.D. from the Cleveland Marshall College of Law.
Dominic Le Moignan
Mr. Le Moignan is a Director with the Secretariat of the International Governance and Risk Institute. He has been responsible for managing projects for the UK Foreign and Commonwealth Office, The American Bar Association, Chartered Institute of Securities and Investment, Qatar Financial Centre, Cayman Islands Monetary Authority, Ministry of National Security Trinidad and Tobago, Integrity Commission Trinidad and Tobago, Czech National Bank, Malaysia Anti-Corruption Commission, Ministry of Justice Belize, Office of National Drug and Money Laundering Control Policy Antigua and Barbuda, Federal Board of Revenue Pakistan as well as several other Central Banks, Revenue Authories, Financial Intelligence Units, Customs and Police Departments and British High Commissions. Mr. Le Moignan is particularly interested in strategies that consider the political realities of corruption rather than simply economic models. He is currently Project Managing initiatives in Chile, Colombia, Cuba, Mexico, Myanmar, Panama, Papua New Guinea and Peru.
William Langford
In 2015, William Langford joined GE Capital as the Chief Compliance Officer where he leads the team responsible for the firm’s global compliance program. Before joining GE Capital, he served as the Global Head of Compliance Architecture & Strategy at Citigroup, where he led the group responsible for compliance risk analytics and assessments, regulatory and data governance, and global compliance strategy. Previously, Mr. Langford held several positions at JPMorgan Chase & Co., including the Global Head of Compliance and Head of Enterprise Financial Crimes Compliance. Mr. Langford has also served as the Associate Director for the Regulatory Policy and Programs Division of the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury. In this capacity, he oversaw the Bank Secrecy Act regulatory, compliance and enforcement functions for the Agency. Mr. Langford previously served as the Senior Advisor to the General Counsel of the U.S. Department of the Treasury, where he focused largely on the implementation of the anti-terrorism and anti-money laundering provisions of the USA PATRIOT Act, including the drafting of regulations implementing these provisions. Prior to joining Treasury, Mr. Langford practiced law with the Washington, D.C. law firm of Williams & Connolly LLP and the Boston law firm of Choate, Hall & Stewart, specializing in commercial litigation. He also served as a law clerk to the Honorable Royce C. Lamberth in the U.S. District Court for the District of Columbia.
Dennis Lormel
Mr. Lormel retired from the Federal Bureau of Investigation (FBI) following over 30 years of government service, for almost 28 years of which he as a Special Agent in the FBI. In December 2000, Mr. Lormel was promoted to Chief of the FBI’s Financial Crimes Program. Immediately following the terrorist attacks of September 2001, Mr. Lormel formulated, established and directed the FBI’s comprehensive terrorist financing initiative. He developed and implemented a variety of proactive and progressive investigative methodologies. These efforts evolved into the formation of a formal Section within the Counterterrorism Division of the FBI, known as The Terrorist Financing Operations Section. Mr. Lormel has received numerous commendations and awards to include the Department of Justice, Criminal Division’s Award for Investigative Initiative and the Central Intelligence Agency’s George H. W. Bush Award for Excellence in Counterterrorism. Over the last ten years Mr. Lormel has provided risk advisory consulting services. He is the founder and President of DML Associates, LLC, a full service investigative consultancy. Mr. Lormel provides consulting services and training related to terrorist financing, money laundering, fraud, financial crimes, suspicious activity and due diligence. He also offers financial intelligence services through case studies and trend analysis. Mr. Lormel was presented with the 2010 Association of Anti-Money Laundering Specialists Volunteer of the Year Award.
Bronwen Macro
Ms. Macro is the BSA/AML Risk Coordinator at the Federal Reserve Bank of San Francisco. In this role, she identifies and monitors emerging BSA/AML and OFAC risks and supervisory issues, provides guidance and consultative services to supervisory staff, and works with counterparts throughout the Federal Reserve System to develop and deploy regulatory guidance. Previously, Macro was a risk examiner in various areas within the Financial Institution Supervision Group at the Federal Reserve Bank of New York. She led BSA/AML examinations of community, regional, and foreign banking organizations, and served as a Senior Examiner in the Counterparty Credit Risk area, where she analyzed and monitored exposure data of large financial institutions. Macro also worked for several years on the Comprehensive Capital Analysis and Review (CCAR). She is a graduate of Brown University.
Willie A. Maddox, CRCM, CRMA, CAMS, CPA
Ms. Maddox is Vice President - Senior Mortgage/Retail Credit Lending Compliance & Risk Manager at Fulton Bank, N.A. Previously, she was Vice President, ERM Risk Assessment Manager at Key Bank, where she led the oversight, management, and administration of ERM risk assessments/risk profiles and dashboard production for the corporation. Earlier she was Vice President and Regulatory Compliance Manager, where she was responsible for program and process management within the Key National Bank Major Lines of Business (KNB). Her responsibilities include managing the planning, development, implementation, training, monitoring, reporting, and tracking of compliance procedures and processes related to Bank Secrecy Act / Anti-Money Laundering (BSA/AML), Office of Foreign Assets Control (OFAC), High Risk Issues/Processes, Risk Assessment, Risk Review Open Issues, Key National Bank Enterprise Compliance, and other regulatory, audit and/or security related requirements. She has an MBA from the University of Chicago School of Business.
John Mair
Mr. Mair is Head of Transaction Advice at The European Bank for Reconstruction and Development (EBRD), and leads the team which advises on the integrity and reputation risk of its investments. He also runs the EBRD’s internal and external capacity building activities on AML/CFT. He previously held senior business roles at Lloyds TSB in Europe and Latin America before becoming its first Group Financial Crime Director. Previously he was appointed Senior Vice President at Western Union, covering risk in 130 countries and 200,000 outlets outside the Americas. John’s interest in ethics, governance, and ‘problems’ led him to serve on a variety of UK and international public and private sector committees. He sits on the Advisory Board of University College London School of Ethics and Laws, and is a Non-Executive Director of the Commonwealth Partnership for Technology and Management. John is a member of Transparency International’s Business Principles Steering Committee, and represents the EBRD at the OECD FATF.
Shaun Mark
Mr. Mark is Forensic Accountant for the Organized Crime & Cyber Group of the Australian Federal Police. A certified Public Accountant, Mr. Mark conducted the financial investigation into the 2002 Bali Bombings in Indonesia with the Indonesian National Police. He also conducted and managed a financial investigation and proceeds of crime investigation over a five-year period into a $500M fraud against the Indonesian Central Bank with the Indonesian National Police. Working with the Asia Pacific Group on Money Laundering, he has also coordinated, managed, and lead the money laundering and terrorism finance typologies function, including the Typology Working Group Meetings in Korea and the Annual Typologies Meeting in India. He has coordinated and lead a team to conduct a review of member countries progress in implementing the recommendations under their mutual evaluation report against the FATF Recommendations for Brunei, Myanmar, the Philippines, Chinese Taipei, and Thailand.
Rick McDonell
Mr. McDonell is Executive Secretary of the Association of Certified Anti-Money Laundering Specialists and a member of the ACAMS Advisory Board. He recently stepped down as Executive Secretary of the Financial Action Task Force, a post he held since 2007. Previously he served as Chief of the UN Global Programme against Money Laundering; founding Executive Secretary of the Asia Pacific Group on Money Laundering; National Coordinator, Legal Advisor, and Public Prosecutor at the Australian National Crime Authority; and Special Prosecutor for the Costigan Royal Commission of Government of Australia, which investigated organized crime in Australia.
Joseph Myers
Joseph (Jody) Myers is Vice President of BSA/AML Risk Assessment at Western Union, where he leads the company’s global AML risk office. Previously, he was assistant general counsel and head of the Financial Integrity Group in the Legal Department of the International Monetary Fund, overseeing assessments and technical assistance, providing specialized support to IMF surveillance and program lending missions, and representing the organization at the Financial Action Task Force and the G-20 Anti-Corruption Working Group. Prior to joining the Fund in 2005, he worked on financial crime, corruption and terrorism issues as a director at the National Security Council at the White House, as a senior advisor to the Under Secretary of the Department of the Treasury, as assistant director and deputy chief counsel of the Financial Crimes Enforcement Network (FinCEN), and in private law practice. Mr. Myers is a graduate of Yale College and Vanderbilt University Law School.
Josée Nadeau
Ms. Nadeau is Senior Chief Financial Crimes-International, for Finance Canada. Ms. Nadeau has lead the Canadian delegation to the Financial Action Task Force (FATF) and to its regional bodies in the Caribbean, South America and the Asia Pacific region, including the coordination of up to twelve departments and agencies. In particular, she led the review of the 2012 international standards for anti-money laundering and countering the financing of terrorism and proliferation as well as the development of the new assessment methodology; lead the on-going assessment of FATF countries and high-risk countries’ compliance against the FATF standards; lead the on-going policy development. Support Canada at the G7/8, G20, the United Nations and the Organization of American States with respect to financial crimes and financial integrity.
Mark Nance
Mr. Nance is an Assistant Professor in the School of Public and International Affairs at North Carolina State University, where he teaches International Political Economy and European politics, and co-directs the Energy & Security Initiative. His research focuses on the formal and informal means of global governance in the global political economy. He recently co-edited Maritime Piracy and the Construction of Global Governance (Routledge, 2012) and has published on the topic in Global Governance and the Journal of International Criminal Justice. His current work includes projects on the development of international anti-money laundering standards, new efforts to counter WMD proliferation, and the use of experimentalist mechanisms in global governance. Nance earned his PhD at the University of Wisconsin-Madison.
Nikos Passas
Mr. Passas is Professor of Criminal Justice, School of Criminology and Criminal Justice, Northeastern University, and Distinguished Inaugural Professor of Collective Action, Business Ethics and Compliance, IACA-International Anti-Corruption Academy, Vienna. He has published more than 170 articles, reports, book chapters, and books in 13 languages on corruption, illicit financial/trade flows, sanctions, informal fund transfers, remittances, white-collar crime, terrorism, financial regulation, and international crimes. Passas is editor-in-chief of the international journal, Crime, Law and Social Change, and served on the Board of Directors of the International Society of Criminology, and as Acting Director of the International Anti-Corruption Academy’s MA Program. He is Chair of the International Advisory Board of the African Centre for Anti- Corruption, Integrity and Accountability; Academic Advisor of the Anti-Corruption Academy of India; and INSPIRE Fellow at Tufts University’s Institute of Global Leadership. Passas holds a law degree from University of Athens, Master’s from University of Paris-Paris II, and PhD from University of Edinburgh Faculty of Law.
Susan Pond
Ms. Pond is Senior Officer, Political Affairs and Security Policy, NATO Headquarters. Ms. Pond has more than twenty-five years experience at NATO and in the Canadian Public Service advising on policy, assessing risks, and developing practical tools to manage change/transformation. Her NATO career led her from the Canadian Coast Guard to Allied Command Transformation and then on to NATO HQ. From the outset she has been closely associated with NATO’s partnership activities. She established the NATO Liaison Office in Ukraine in 1999. Returning from Kyiv she took on responsibilities as Head of NATO’s Partnership for Peace Section at NATO HQ. She has been at the center of NATO’s efforts to build capacity and promote good practice in the defense and security sector. She is the architect of the Partnership Trust Fund Policy and responsible for the design and implementation of the Building Integrity Programme aimed assessing risks and reducing the risk of corruption in the defense and security sector. She is currently a Senior Officer in the Political and Security Affairs Division at NATO HQ.
Karim Rajwani
Mr. Rajwani is Global Head of Anti-Financial Crime IT Strategy at Deutsche Bank. He has more than 30 years of risk management, compliance, and financial accounting experience. Previously, he was Global Head for the RBC Financial Group, responsible for leading RBC's anti-money Laundering, anti-terrorism, client risk management, and anti-bribery initiatives globally. Rajwani was also a member of the Advisory Council on National Security for the Office of the Prime Minister of Canada, Co-Chair of the Canadian Chapter of the Association of Certified Anti Money Specialists (ACAMS), and is on the Advisory Board of ACAMS. Rajwani is a Chartered Accountant both in Canada and the UK, and has worked for various financial, chartered accounting, and management consulting firms. In these roles he has overseen the implementation of a number of enterprise-wide risk management and compliance initiatives.
Jason Sharman
Mr. Sharman is a Professor at the Centre for Governance and Public Policy, Griffith University, Australia. His research is focused on corruption, money laundering, and offshore financial centers. For his most recent book Global Shell Games (Cambridge University Press, 2014) co-authored with Michael Findley and Daniel Nielson, he tested the effectiveness of beneficial ownership standards by impersonating corrupt officials, money launderers, and terrorist financiers and making 7400 solicitations for anonymous shell companies. Sharman's earlier books include The Money Laundry (Cornell University Press, 2011); The Puppet Masters, co-authored with a World Bank team in 2011; and Corruption and Money Laundering, with David Chaikin in 2009. He has worked as a consultant with the Stolen Asset Recovery Initiative, Financial Action Task Force, Asia-Pacific Group on Money Laundering, and Commonwealth Secretariat.
Richard Small
Mr. Small recently joined Ernst & Young LLP as Senior Advisor, Anti-Money Laundering and Financial Crimes, Financial Services Office. He brings leading insights on the challenges, strategies, regulatory expectations, and future focus areas for antimoney laundering and financial crimes at a global level. Prior to joining EY, Rick was Senior Vice President, Enterprise Wide Anti-Money Laundering, Anti-Corruption and International Regulatory Compliance for American Express, and was responsible for the enterprise-wide anti-money laundering, anti-corruption, and sanctions programs; and for the Compliance teams that manage day to day compliance outside of the US. Previously Small was Global Anti-Money Laundering Leader for GE Money, and was responsible for the anti-money laundering program of their businesses globally. Prior to joining GE, he was the Managing Director, Global Anti-Money Laundering, for Citigroup. Earlier in his career, Small held positions as a Federal Prosecutor with the US Department of Justice in the Antitrust Division and the Organized Crime Strike Force as the Senior Counsel for Law Enforcement with the US Department of the Treasury and his most recent government position was on staff of the Federal Reserve System Board of Governors. Small was Deputy Associate Director in the Division of Banking Supervision and Regulation with responsibility for the enforcement and special investigations functions of the Federal Reserve, including all Bank Secrecy Act and money laundering matters, and for conducting investigations of complex financial transactions, suspicious activities, and related enforcement actions. Small is currently Chairman of the Advisory Board of the Association of Certified Anti-Money Laundering Specialists, and a member of the Advisory Board for the American Bankers Association/American Bar Association Money Laundering Enforcement Conference.
Kevin M. Stephenson
Mr. Stephenson is Executive Secretary of the Egmont Group of Financial Intelligence Units. Before joining the Egmont Group, he was a Senior Financial Sector Specialist with the Financial Market Integrity Unit at the World Bank. Prior to joining the World Bank, he was Anti-Corruption advisor for the United National Integrated Mission in Timor-Leste. He also served as the Director of the Financial Intelligence Centre for the United Nations Interim Administration Mission in Kosovo combating money laundering and terrorism financing. He has also worked as a Deputy Attaché for the Department of Homeland Security and a Special Agent at the Department of Treasury. He holds a MS in Criminal Justice from the University of Tennessee.
Braddock Stevenson
Mr. Stevenson is currently the section chief overseeing FinCEN’s investigations of depository institutions for compliance with the Bank Secrecy Act. Braddock has been with FinCEN since 2007. Braddock has worked in Bank Secrecy Act enforcement since 2012. He has also worked in FinCEN’s Office of Regulatory Policy. During this tenure, Braddock investigated domestic financial institutions under the Bank Secrecy Act and implemented and interpreted regulations on prepaid cards, money services businesses, cross-border transmittals of funds, and currency transaction reports. His responsibilities also included investigating and drafting section 311 actions and representing FinCEN in intra-agency task forces. While with the Office of Regulatory Policy, Braddock was stationed in the New York High Intensity Financial Crimes Area where he advised law enforcement investigators and analysts on money laundering investigations. He earned his J.D., cum laude, from Case Western Reserve University and a B.A. in history from The Pennsylvania State University. Braddock was a Senior Research Fellow in financial sector integrity for both the World Bank Group and the International Monetary Fund.
Daniel P. Stipano
Mr. Stipano is the deputy chief counsel for the Office of the Comptroller of the Currency. He served as Acting Chief Counsel from October 2004 to August 2005, and from October through December 2012. As deputy chief counsel, Mr. Stipano supervises the OCC’s Enforcement and Compliance, Litigation, Community and Consumer Law, and Administrative and Internal Law Divisions. He also supervises the OCC district counsel staffs in the OCC’s Southern and Western Districts. From 1995 to 2000, Mr. Stipano served as the director of the OCC’s Enforcement and Compliance Division. In this position, he headed the division that was responsible for taking administrative enforcement actions against national banks and their institution-affiliated parties. From 1989 to 1995, Mr. Stipano was an assistant director in the Enforcement and Compliance Division, after joining the OCC in 1985 as a staff attorney in the division. A member of the Virginia State Bar and the American Bar Association, Mr. Stipano also represents the OCC on the Treasury Department’s Bank Secrecy Act Advisory Group and the National Interagency Bank Fraud Working Group. Mr. Stipano received his JD degree from the Marshall-Wythe School of Law, College of William and Mary in 1983. He also received a BA degree, summa cum laude, from Union College, in 1980, where he earned Departmental Honors in Political Science and was elected Phi Beta Kappa.
John E. Sullivan III
Mr. Sullivan is a founding member of Sullivan & Sullivan, Ltd. His practice areas include asset protection planning, estate planning, business planning, and related tax issues, among others. He has written and lectured extensively on these topics, and his works have been cited and/or quoted by various courts and in the official comments to the Uniform Trust Code. Mr. Sullivan has also been involved in various legislative projects related to trust, company, and debtor-creditor law. He also serves as an expert witness in cases involving allegations of flawed or improper planning. He received his J.D. from the University of Texas at Austin.
Jim Vivenzio
Mr. Vivenzio is the Senior Counsel for BSA/AML for the Office of the Comptroller of the Currency (OCC) in Washington D.C. In this position, Mr. Vivenzio serves in the Chief Counsel’s Office and reports directly to the Deputy Chief Counsel. His areas of practice mainly involve Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance policy and enforcement matters, and operational and fraud risks involving payment systems. Mr. Vivenzio is a member of the Interagency Cybercrime Working Group, the Interagency Payments Fraud Working Group, various Bank Secrecy Act Advisory Group (BSAAG) Subcommittees, and the FS-ISAC Payments Fraud Working Group. Mr. Vivenzio previously served as the OCC’s Special Assistant to the Deputy Chief Counsels and as the Acting Senior Advisor to the Senior Deputy Comptroller for Bank Supervision Operations. From 1991 to 2000, Mr. Vivenzio served as a Senior Attorney in the OCC’s Northeastern District Office in New York City where he worked on various bank advisory, licensing and BSA/AML enforcement matters. Mr. Vivenzio began his career as an associate with the law firm White & Case in New York City. He received his J.D. degree from the Fordham University School of Law and worked as a senior auditor with Coopers & Lybrand while attending law school in the evening. He received a B.S. degree from the Fordham University College of Business Administration and was a member of the Beta Alpha Psi accounting honor society. Mr. Vivenzio is a member of the New York Bar, the New Jersey Bar and the New York State Bar Association.
Emile van der Does de Willebois
Mr. van der Does de Willebois is a Global Leader, Financial Market Integrity and Senior Financial Sector Specialist at the World Bank. He specializes in issues of abuse of legal entities, beneficial ownership, and the use of non-profit entities for terrorist purposes. At the World Bank’s Financial Market Integrity unit, he was involved in technical assistance (legislative drafting and training) to Eastern Asian Pacific countries on Anti Money Laundering and Counter Terrorism Financing (AML/CFT). Previously he worked in private practice specializing in banking and securities law. He started his career at the Office of the Prosecutor at the International Criminal Tribunal for the former Yugoslavia in The Hague.

CWRU Law Faculty Members


Jonathan Adler
Johan Verheij Memorial Professor of Law; Director, Center for Business Law and Regulation

Michael Benza
Senior Instructor in Law

Juscelino Colares
Schott-van den Eynden Professor of Law; Associate Director, Frederick K. Cox International Law Center

Richard Gordon
Director of the Financial Integrity Institute; Associate Director of the Frederick K. Cox International Law Center; Professor of Law

Michael Scharf
Dean and Director of the Frederick K. Cox International Law Center, Joseph C. Hostetler - BakerHostetler Professor of Law

Timothy Webster
Assistant Professor of Law Director of Asian Legal Studies
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