Common Knowledge: Information Sharing Under 314(b) of the USA PATRIOT Act

Craig Timm is the Senior Director of AML at ACAMS.

Prior to joining ACAMS, Craig had more than 15 years of anti-financial crime experience across the public and private sectors. At the Department of Justice, Craig served as a Deputy Chief in the Asset Forfeiture and Money Laundering Section (now Money Laundering and Asset Recovery Section) at headquarters in Washington, DC. In that role, he led a team of prosecutors responsible for enforcing criminal violations of the Bank Secrecy Act, U.S. economic sanctions, and money laundering laws committed by financial institutions and their employees. He led the prosecution of some of the largest financial institutions in the world including HSBC and BNP Paribas. Craig began his career with the Department of Justice as an Assistant United States Attorney in Arizona. At the Department of Justice, he was the recipient of numerous awards including the Attorney General’s Crime Victim’s Restoration Award, the Assistant Attorney General’s Award for Exceptional Service, and the Immigration and Customs Enforcement Director’s Meritorious Service Award.

At Bank of America, Craig was a Financial Crimes Executive responsible for Strategic Initiatives. These initiatives included participation in the Bank Secrecy Act Advisory Group, 314(b) information sharing initiatives, and the Wolfsberg Group as well as managing the day-to-day liaison with FinCEN, the U.S. Treasury, senior financial crimes policy officials at the OCC and Federal Reserve, key law enforcement agencies, and the U.S. Department of Justice. He also spent several years as the Financial Crimes Executive for the Global Wealth and Investment Management business lines where he served as the designated Anti-Money Laundering Compliance Officer for Merrill Lynch and U.S. Trust.

Craig has an undergraduate degree from the University of Michigan and a law degree from the Northwestern University School of Law.

Ms. Forman is TD's Head of U.S. Investigations, that is comprised of both the AML Investigations team and Specialized Investigations teams.  The Investigations unit addresses financial crime risk, that includes anti-money laundering, sanctions evasion, terrorist finance, anti-bribery and corruption and insider risk.

Prior to joining TD, Ms. Forman was with Citigroup for 13 years as the Managing Director for the Global Financial Crimes Investigations and Intelligence unit (GFCII).  The GFCII’s function is to conduct complex global investigations across financial crimes risks, including anti-money laundering, sanctions, terrorist finance, anti-bribery and corruption, and other illicit activity that poses a risk to the bank. Under Ms. Forman’s leadership, the GFCII initiated proactive, complex global investigations of high-risk clients. The enterprise-wide nature of the GFCII investigations requires coordinated analysis of client activity in multiple jurisdictions and business sectors.

Prior to joining Citigroup, Ms. Forman served as the Independent Court Monitor for the Western Union and State of Arizona judicial settlement. Ms. Forman served for over five years as the Director, Office of Investigations, Homeland Security, where she oversaw the largest investigative arm for DHS, with over 6,200 Special Agents and administered a budget of more than $1.6 billion.  Ms. Forman was the architect and Executive Director of Operation Green Quest, a highly successful U.S. Department of Treasury led multi-agency task force that was immediately established after September 11, 2001 to address the threat of terrorist financing. Ms. Forman is currently an Adjunct Professor at Fordham University School of Law, where she instructs law students on AML Compliance and Terrorist Financing.

Ms. Forman continues to be an active participant in ACAMS as a subject matter expert and participates regularly in workshops, webinars and conferences. In addition, Ms. Forman served as the Citibank Representative to the Wolfsberg Group and in that capacity sat on the Terrorist Finance and Investigative Benchmarking sub-working groups. Ms. Forman was Citibank’s representative to the Board of Directors for the Consortium, an association of banks established under the authority of the U.S. Patriot Act.

Ms. Forman is the recipient of the prestigious Presidential Rank award for meritorious service, the Women in Federal Law Enforcement President’s award and the Secretary of Homeland Security’s Silver Medal for leadership. Ms. Forman holds a Master of Science degree in Management from National-Louis University, a Bachelor of Science degree from American University and has completed the Senior Executive Fellowship Program for Leadership at Harvard University.

Ms. Forman is an exercise enthusiast when not at work and enjoys traveling the world. Ms. Forman enjoys spending time with her husband of 36 years and her two daughters.

Nick Maxwell leads the Future of Financial Intelligence Sharing (FFIS) research programme, hosted within the Royal United Services Institute (RUSI) Centre for Financial Crime and Security Studies. The mission of the FFIS programme is to examine evidence related to the effectiveness, proportionality and efficiency of public-private and private-private information sharing partnerships and processes, and to share good practice between existing partnership models around the world. Prior to this role, Nick’s professional career has included Head of Research and Advocacy for Transparency International UK; providing anti-money laundering specialist advice to NATO; managing the International Economics Programme at Chatham House (the Royal Institute of International Affairs); and leading the public policy function at the Institute of Chartered Accountants in England and Wales.

Sarah K. Runge is an executive managing director in K2 Integrity’s Financial Crimes Compliance practice. She works with fintech firms and financial institution clients to review and improve their financial crime compliance policies and practices to ensure compliance with U.S. and global requirements. Sarah helps clients develop and implement relevant financing policies, procedures, and risk assessment tools, with a focus on digital assets and other emerging technologies and cross-border payments.

Prior to joining K2 Integrity, Sarah was global director of regulatory compliance policies, programs, and governance at Meta FinTech Compliance (a division of Meta), where she led teams responsible for managing global compliance programs including policies, governance, outsourcing, exam management, internal audit, and all aspects of issue management (ingestion, remediation, and closure). Her department managed all licensed and regulated products in Brazil, Ireland (for the EU), the U.K., and the United States, including regulatory engagement, risk assessments, training, regulatory reporting, exam responses, and compliance with AML requirements.

Before her time at Meta, Sarah was the global head of FCC regulatory strategy for Credit Suisse’s financial crime compliance division, where she developed and managed a global regulatory risk management and communication strategy, including creating a global process to identify and analyze new regulations, guidance, policies, and enforcement actions that impact the bank and creating a process to assess and compare regulatory exams and internal audits globally to improve exam and internal audit preparedness and outcomes. She also provided advisory guidance to the bank’s New York branch related to Bank Secrecy Act (BSA) requirements including Customer Due Diligence (CDD), Section 312 of the USA PATRIOT Act, and other regulations.

Prior to Credit Suisse, Sarah spent over ten years in the U.S. Treasury Department’s Office of Terrorist Financing and Financial Crimes, the last five as the director of the Office of Strategic Policy. Sarah led a team that developed domestic and international initiatives to address illicit finance through work with supervisors, law enforcement, and policy makers in the United States and globally. Her work included leading the U.S. delegation to the Financial Action Task Force (FATF) and representing the U.S. Treasury Department at the G-7, the G-20, and the Financial Stability Board.

A thought leader in the financial crimes compliance space, Sarah speaks regularly at events globally on a wide variety of AML/CFT topics, including the BSA and regulatory developments (including AMLA 2020), the use of new technologies, financial transparency including CDD and beneficial ownership, the FATF recommendations and global implementation of AML/CFT measures, de-risking, barriers to information sharing, and correspondent banking.

Sarah holds a M.A. in international affairs from Johns Hopkins University, with concentrations in international economics and European studies, and a B.A. in history, with a minor in German studies, from Scripps College.