| Kenneth L. Bryant |
Anti-Money Laundering |
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of
Kenneth L. Bryant
MSCJ, CPP, CFE, CRP, CAMS, AMLP, AML, COMP, FICA, FCoI
Mr. Bryant has
more than twenty years senior management experience both in the United States and
Overseas as a money laundering investigator, compliance officer/money
laundering reporting officer, enforcement regulator and a counter terrorism and
counter narcotics consultant. He has been awarded a Master of Science degree in Criminal Justice,
summa cum laude, and holds or has held eight board certifications covering the areas of risk
management, financial due diligence, financial operations, regulatory
compliance, and anti-money laundering.
For the past several years, Mr. Bryant has served as a consultant and senior
Subject Matter Expert (SME) on large bank (both foreign and domestic)
remediations, usually where there is regulatory enforcement action. Prior
to that,
Mr. Bryant served as the Director and Product Developer for KYCuOutsourced
Services, a Division of Internet Financial Services [IFS], Ltd. Mr. Bryant
assisted Financial Services Providers (FSP's) in the Banking, Trust, Securities,
Mutual Fund, Company Management and Insurance sectors. At IFS, he was
responsible for product development, overseeing the provision of the due
diligence investigative process, the collection and retention of compliance
records, a suspicious activity reporting mechanism for FSP's and the training of
FSP's employees on anti-money laundering techniques and practices.
Mr. Bryant is a former Senior Manager, Regulatory Compliance, for KPMG in the
Cayman Islands where he was responsible for establishing the first dedicated
regulatory compliance consulting practice on the island. During that time, Mr.
Bryant was seconded to the Cayman Islands Monetary Authority (CIMA) to assist in
the establishment of their Compliance (Enforcement) Division. In that capacity,
Mr. Bryant routinely liaised with each of the Industry Sector Divisions, as well
as with Legal, Policy and Research and the Financial Reporting Unit (FRU). Mr.
Bryant was directly involved in the process which resulted in the FATF
officially removing the Cayman Islands from Non-Cooperative
Countries or Territories (NCCT) status, commonly referred to as the "Black List."
Prior to joining KPMG, Mr. Bryant was a Senior Consultant to Ambassador Morris
D. Busby (former Ambassador at Large for Counter Terrorism and US Counter Terrorism
Coordinator) in Washington,
D.C., specializing in global Counter Terrorism and Narcotics issues, two of the
most influential driving forces in the international Anti-Money
Laundering/Combating the Financing of Terrorism (AML/CFT) effort today. Mr. Bryant
has also held five Corporate and Financial Compliance Officer/MLRO roles in
which he was responsible for designing, writing, implementing, administering and
monitoring effective compliance programs for multi-national corporations with
substantial interests overseas. In addition to being a former investigator and
consultant with the U.S. Government, he was also a Consultant with Plave,
Goldberg & Manten, an international forensic financial fraud investigation and
litigation support firm specializing in AML. During this time, one of the
projects Mr. Bryant was involved in included the detection, investigation, and
prevention of Money Laundering for a major offshore international banking centre
in the Caribbean. As a Chief Fraud Investigator for Washington Mutual, one of
the largest financial institutions in the U.S., he successfully investigated all
internal and external losses in South Florida, considered by some to be the
fraud capital of the world, ranging from government medical assistance fraud to
embezzlement to Money Laundering. Mr. Bryant is also the former global Manager
of the Special Investigations (Financial Fraud and White Collar Crime) Division
of Pinkerton/Securitas, the largest investigative services firm in the world.
Mr. Bryant is a subject matter expert with respect to U.S. and International
banking laws, rules and regulations, audit and examination codes and guidelines
for best practice techniques concerning anti-money laundering, know your
customer/enhanced due diligence, training, record keeping, and suspicious
activity recognition and reporting. He is a frequent presenter and lecturer on
AML/CFT Legislation, Regulation and Guidance Notes; regular media guest and
author/contributor to international programs and articles on offshore finance
and global AML issues, international standards and industry best practices; and
has worked closely with the authors of the "Review of Financial Regulation in the Caribbean Overseas
Territories and Bermuda" as presented to United Kingdom Parliament by the
Secretary of State for Foreign and Commonwealth Affairs (formerly known as the
original Overseas KPMG Report), and with the authors of the Cayman Islands
financial services Legislation, Regulation, and the Guidance Notes, which is
considered by some to be one of the strongest and best practice anti-money
laundering regimes in the world.
Mr. Bryant has been the developer of the AML Intelligence Bulletin, the
Intelligence Watch List Database of known high risk individuals and entities,
the Bank Secrecy Act (BSA) Self-Audit Checklist tool, the Compliance Bulletin, various on-line computer based training (CBT) and compliance professional
development tools, and the Regulatory Compliance Forum, of which he is also the
Moderator. He has extensive experience in writing compliance policy and
procedure manuals; developing and presenting AML training programmes for target
audiences which are both general and industry sector specific; conducting AML
reviews; tailoring and implementing due diligence checklists; designing
retrospective due diligence programs and risk assessments; and integrating IT
managed solutions for compliance and due diligence acquisition and record
keeping. He is considered by many to be the first and one of the foremost knowledgeable
experts in the creation and maintenance of high risk databases using open source
information on a global basis. Mr. Bryant was also the first proponent to
develop a working Electronic KYC (eKYC) model and has been the original creator
behind the idea of an International Registry of Due Diligence Documentation, a
similar version of which has now been called for by the Wolfsberg Group and
supported by the Basel Committee. Mr. Bryant has also played a recent active role
in calling for various agencies of the U.S. Government, the European Union, and
Interpol to more effectively consolidate and disseminate official sanction and
wanted lists.
Mr. Bryant has also provided technical training assistance to the Caribbean Anti-Money Laundering Programme (CALP), the Financial Reporting Unit (FRU)/Financial Intelligence Unit (FIU), and the Commercial Crime Branch (CCB) of the Royal Cayman Islands Police (RCIP). He has also presented and published widely on the new International Monetary Fund (IMF)/World Bank AML/CFT Review Methodology. Mr. Bryant has served as an advisor to the Commissioner of Police and the “Top Management Team” of the Royal Cayman Islands Police Service during a recent IMF/World Bank Review of the Cayman Islands in September 2003. The Cayman Islands represent the largest offshore financial jurisdiction in the world and are ranked as the fifth largest financial jurisdiction overall after New York, London, Hong Kong and Toyko.
Mr. Bryant is a Fellow and the former Chairman of the Eastern Seaboard of the Americas Region (Latin America and the Caribbean) for The Compliance Institute, the oldest and largest association of compliance professionals in the world. He is a Fellow of the International Compliance Association (ICA), and holds two internationally accredited university level diplomas, one in AML and the other in Compliance. Mr. Bryant is also a Certified Anti-Money Laundering Specialist and Professional Charter Member of the Association of Certified Anti-Money Laundering Specialists and has served on their Certification, Education, and Technology Task Forces. He has been a Certified Fraud Examiner, Certified Protection Professional, Certified Risk Professional and a Certified Anti-Money Laundering Professional. Mr. Bryant was also a founding participant in the International Association of Integrity Management (IAIM), an international body whose mission is to set standards for professional compliance associations worldwide. As a member of the Training and Accreditation Committee, the first mandate has been to develop an internationally accepted and standardized professional certification and code of ethics. Mr. Bryant has recently co-founded a Best Practices and Industry Standards Group for the US Financial Services Industry, through which he chaired the Steering Committee of the Council of Standards and Practices for the National Money Transmitters Association (NMTA).
Mr. Bryant is consistently rated by conference attendees as a "passionate," "dynamic," and "engaging" speaker who delivers step by step practical solutions to complex compliance issues. He currently resides in the United States where he manages and operates a global asset protection and risk mitigation consultancy. He advises governments, international bodies, regulatory agencies, financial institutions, consulting firms, and AML vendors on a global basis.