Developing Risk-Based Strategies for Banking Designated Non-Financial Businesses and Professions

  • When: January 29, 2020
  • Time: 12PM – 2PM ET
  • Level: All

Law firms, real estate agencies, precious metals dealers and gaming organizations: These are just some of the designated non-financial businesses and professions (DNFBPs) that pose unique opportunities — and distinctive anti-financial crime (AFC) risks — for financial institutions. Join our panelists for an authoritative analysis of the complicated, but surmountable challenges for safely onboarding DNFBPs and developing oversight protocols that meet both regulatory requirements and your institution’s risk appetite and tolerance standards.

Learning Objectives

  • Analyzing unique risks of specific DNFBP sectors such as real estate, legal practitioners and gaming to assess nature of institutional exposure
  • Reviewing guidance from FATF and regulatory guidance on DNFBPs to gain insights on best practices in areas such as KYC/CDD and beneficial ownership
  • Designing and implementing risk-based models specific to DNFBPs to ensure adequacy of internal controls, monitoring, and red flag detection and resolution

Who Should Attend

  • Compliance Officers
  • Risk Managers
  • Gaming Organizations
  • Professional Services Providers
  • Real Estate Agencies
  • Precious Metals/Gems Dealers


  • Global
  • North America
  • Banking


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  • Ali Moghaddam, JD, CAMS

  • Senior Vice President – BSA & OFAC Officer
  • City National Bank


Mr. Ali Moghaddam is an AML & Compliance executive with 10+ years of experience developing and implementing BSA/AML and OFAC programs and investigating financial crime, money laundering and terrorism financing. He is currently the BSA & OFAC Officer for City National Bank where he is responsible for developing, implementing and administering all aspects of the bank’s Anti-Money Laundering (“AML”), Sanctions and Anti-Bribery and Corruption (ABAC) program. Prior to joining City National Bank, Ali spent time working as a subject matter expert at Promontory Financial Group, where he worked with different financial institutions to strengthen their AML and Sanctions programs. Ali began his private sector career as the Head of Investigations for UBS Financial Services, the Americas. At UBS, his team was responsible for investigating and reporting all potential money laundering, terrorism financing, cross border and fiscal compliance issues for UBS, Americas. Ali began his career as a prosecutor, working as an Assistant District Attorney for the Montgomery County District Attorney’s Office where he was assigned to the major crimes unit and successfully prosecuted several major cases including a capital murder case. Following his recruitment, he joined the FBI as a Special Agent in 2009. As a Special Agent, Ali was initially assigned to the Joint Terrorism Task Force (JTTF) in Los Angeles where he also worked closely with the Violent Criminal Multi-National Organization (VCMO) squads, and the Counter-Intelligence & Counter-Proliferation (CI) squads. During his time as a special agent, Ali investigated matters involving anti-money laundering, terrorism financing, counter proliferation/ OFAC violations, gangs and drug cartels. Ali spent his last 3 years in the public sector as a member of the FBI’s  High Value Target Team where he liaised with federal intelligence and law enforcement partners in pursuit of the high value targets. Ali received his BS in Political Science from UCLA, completed his MS coursework in Near Eastern and Latin American History from Cal State Los Angeles and he received his JD from Temple University, Beasley School of Law.


Brian Frankel
  • Brian Frankel, CAMS, CFE

  • Manager, Risk Advisory Services
  • Kaufman Rossin


Brian has extensive experience in complex financial crime and compliance matters in the public and private sector. He currently leads a team conducting program risk assessments, consent remediation, and model tuning/calibration engagements nationwide. Brian has helped develop custom RPA and anomaly detection models for many institutions as well. Prior to joining Kaufman Rossin Brian lead a team of AML investigators at Citibank conducting high risk reviews in the areas of trades based money laundering, human trafficking, and foreign corruption. Brian speaks across the country at various events with the ACAMS and has been published in a global journal on the subject of human trafficking risks in the U.S. Brian is currently on the Board for the ACAMS South Florida Chapter. He is also currently pursuing his Masters of Science in Data Analytics with Texas A & M University.

Angel Swift
  • Angel Nguyen Swift, CAMS

  • Chief Collaborator
  • ASCollabs

Angel Nguyen Swift is an advisor and independent consultant with Enigma Technologies, a data intelligence company, where she most recently worked as the Vice President of Compliance and Financial Crimes Solutions. She is also the creator of the STAT (Stand Together Against Trafficking) project, which connects the anti-human trafficking community to identify and share financial indicators of human trafficking activity. To further this mission, she has partnered with Polaris, ACAMS (Association of Certified Anti-Money Laundering Specialists) and Enigma, to leverage technology to empower the sharing of these financial indicators across the anti-financial crime community.

At Enigma, she led strategic initiatives focused on bringing augmented intelligence to help financial crime professionals make informed decisions effectively. Her work included helping financial institutions assess their current AML processes to identify areas where technology could strengthen and close gaps in their programs. In addition, Angel has been called upon by financial institutions to assess and develop strategic initiatives to build and restructure their financial intelligence units (including SAR investigations, EDD, KYC Refresh, sanctions/PEP screening and review, transaction monitoring, information sharing program). Angel has also led and advised on product research initiatives to develop Enigma’s Screen product, a watchlist screening engine which deploys a methodology premised on advanced data matching algorithms and machine learning. Research and development included deepdives into sanctions screening processes at financial institutions.

Prior to Enigma, Angel spent nearly a decade building and leading the financial intelligence unit (FIU) at American Express. Under her leadership, the FIU expanded from five people focused on the U.S. card business to nearly 500 people supporting the enterprise in more than 40 countries. As VP of the FIU, Angel was responsible for establishing and maintaining an end-to-end program that supported the suspicious activity reporting process, including transaction monitoring rule development, quality control, sanctions screening and investigations, enhanced due diligence reviews, KYC refresh, anti-corruption and bribery monitoring and investigations, and special investigations. Her responsibilities also included leading development of technology solutions for the FIU, managing regulatory examinations conducted by all federal and state agencies, and spearheading the development, implementation, and presentation of large-scale remediation efforts related to the company’s AML program.

  • Raymond Villanueva

  • Special Agent in Charge
  • Homeland Security Investigations


Ray Villanueva serves as the Special Agent in Charge for Homeland Security Investigations (HSI) Washington, D.C. In this position, he oversees HSI’s field operations and investigative efforts in the District of Columbia and the states of Virginia and West Virginia. His office includes a broad cadre of special agents, intelligence analysts, and professional administrative personnel further assigned to several sub-offices, operational groups and task forces to include two HSI led Border Enforcement Security Task Forces. Mr. Villanueva is responsible for leading investigations into transnational crimes and threats, specifically disrupting and dismantling terrorist, transnational and other criminal organizations that threaten or seek to exploit the customs and immigration laws of the United States.

Prior to his current assignment, Mr. Villanueva served an Assistant Director for HSI. In his role he oversaw the Office of International Operations where he was responsible for a budget of more than $180 million and the operational oversight of 68 offices in 51 countries and 8 Department of Defense liaison offices with over 400 personnel. Mr. Villanueva has more than 25 years of law enforcement experience.

Mr. Villanueva began his law enforcement career in 1994 as a Police Officer with the Puerto Rico Police Department (PRPD) where he was subsequently promoted to a criminal investigator position assigned to the U.S. Customs Service Task Force, Office of the Special Agent in Charge San Juan. In 2015, due to his constant engagement and support to the mission of the PRPD, Mr. Villanueva was promoted to the rank of Honorific Lieutenant Colonel, the second highest rank within the police department.

Since joining HSI, Mr. Villanueva has served in numerous key positions ranging from group supervisor for the Financial Crimes Group at HSI Buffalo, NY, section chief for the Illicit Finance and Proceeds of Crime Unit in Washington, DC, unit chief for the Trade Transparency Unit in Washington, DC, Assistant Special Agent in Charge for HSI San Juan, Deputy Assistant Director for HSI International Operations and as an Assistant Director for HSI. Mr. Villanueva has been a member of the Senior Executive Service since 2015.

Mr. Villanueva is a member of the International Association of Chief of Police (IACP) where he currently serves as the International Vice President and Chair of the Global Policing Division.