Robert Pasley (CAMS) was most recently a Senior Vice President in the AML policy area for Bank of America. Prior to that, he served as a contractor for FinCEN, working on policy issues, handling specific cases, and assisting in drafting the final 312 regulation. Before that, he was an Assistant Director of the Enforcement and Compliance Division of the Office of the Comptroller of the Currency and specialized in the AML area. He is a graduate of the Cornell Law School and of the Stonier Graduate School of Banking. His honors thesis at Stonier was on the Consolidation of the Banking Agencies. He has also written on several other topics, including a chapter on the History of the Banking Agencies’ Enforcement Powers, a law review article on the impact of the Double Jeopardy Clause on civil money penalties, a law review article on the tension between privacy rights and anti-money laundering enforcement and a law review article on developments in Bank Secrecy Act enforcement.