AFC in Practice: Using Behavioral Analytics to Identify Suspicious Activity

Eugene is a senior compliance manager, currently serving as Head of Transaction Monitoring in Mashreqbank,  experienced in building risk-based BSA/AML programs and managing regulatory remediation projects in a number of global financial institutions. He’s an expert in building highly effective operational mitigation controls for high risk products, including foreign correspondent banking, institutional and corporate banking, global trade finance and SWIFT/FED/CHIPS payments.

Eugene designs and implements BSA/AML compliance framework, including Transaction Monitoring Unit (TMU) and Financial Investigation Unit (FIU) operational management, risk coverage assessment reviews, BSA/AML model development and validation, detection scenarios tuning methodology, and AML Coverage Assessment, comprising the pillars of successful BSA/AML risk management enterprise, in collaboration with principal stakeholders and executive management.

Prior to entering banking industry, Eugene served as a criminal investigator for 14 years, investigating and supervising cases of money laundering, organized crime, domestic terrorism, financial and insurance fraud.

Frank P. Calestino is an internationally recognized subject matter expert on healthcare fraud, terror financing, the global hawala system, international financial sanctions, and counter-threat finance intelligence and law enforcement operations. He currently leads the Behavioral Analytics Team for Global Financial Crimes at Bank of America.

Mr. Calestino joined Bank of America in January 2016. Prior to this, he served over a decade with the U.S. Federal Government, spending most of his career overseas establishing and leading counter-threat finance cells for the U.S. Department of the Treasury. Mr. Calestino joined Treasury’s Office of Intelligence and Analysis (OIA) in September 2005 as a Presidential Management Fellow and was named Co-Director of the Iraq Threat Finance Cell (ITFC), a U.S. government interagency counter-terror finance task force, in July 2006. During his year-long tenure as ITFC’s chief counter-threat finance analyst in Baghdad, Iraq, Mr. Calestino assembled and led a team of federal law enforcement agents and intelligence analysts tasked by the U.S. National Security Council to identify and disrupt terrorist and insurgent finance networks. In 2007, he was named the Department of the Treasury’s Liaison to U.S. Central Command (CENTCOM) in Tampa, Florida. During his assignment at CENTCOM, Mr. Calestino drafted the concept paper for the Afghanistan Threat Finance Cell (ATFC), which he established in 2008 with colleagues from the Drug Enforcement Administration (DEA), the Department of Defense (DOD), and other interagency partners. Mr. Calestino served as the Treasury Department Deputy Director of the ATFC in Afghanistan from 2008 - 2011 and again from 2012 – 2013. He then took a position with the Investigations Directorate of the Special Inspector General for Afghanistan Reconstruction (SIGAR) as the supervisory intelligence analyst responsible for financial crimes investigations at the U.S. Embassy, in Kabul, Afghanistan.

In addition to his duties at Bank of America, Mr. Calestino also serves as a consultant for the United Nations’ Office on Drugs and Crime (UNODC) Global Program against Money Laundering (GPML). His most recent assignments for UNODC entailed leading anti-money laundering, counter-terror financing, and counter-proliferation financing training missions in the Democratic Republic of the Congo, Namibia, Angola, Kazakhstan, Papua New Guinea, and Vietnam.

Mr. Calestino is the recipient of the Secretary of the Treasury’s Honor Award, the Department of Defense’s Joint Meritorious Civilian Service Medal, Individual Meritorious Civilian Service Medal, and Joint Meritorious Unit Award (ATFC). In 2012, he received the National Intelligence Superior Service Medal from then Director of National Intelligence James Clapper. He has also been awarded Superior and Meritorious Honor Awards from the Department of State. In 2010, he was nominated for the Samuel J. Heyman Service to America Medal by the Partnership for Public Service for his role in establishing and leading the ATFC. In 2014, he received the Secretary of Defense’s Medal for the Global War on Terrorism.

Mr. Calestino received his B.A. from the University of Rhode Island in 1998 and holds Master of Arts degrees from the European University in St. Petersburg, Russia (1999) and Georgetown University (2005).

Jenni Halleran is the Deputy BSA Officer and Head of Financial Crimes Investigations at First Citizens Bank and Silicon Valley Bank. In this role, Jenni oversees all financial crimes investigative and operational functions, and spearheads the development and modernization of financial crimes risk management approaches across the enterprise.

Jenni is especially passionate about the importance of building stellar working relationships with key stakeholders, and creating organizational cultures that consistently produce high-performing and highly engaged teams.

Prior to joining First Citizens Bank and Silicon Valley Bank, Jenni held various roles at American Express, where she drove initiatives such as financial crimes training, led large teams of investigators, and initially, investigated financial crimes herself. Jenni holds a Juris Doctorate degree from the University of Idaho and a Bachelor’s degree in Law, Society, and Justice from the University of Washington