Mullett joel r cv 2011 compliance and risk management executive

JOEL MULLETT

617.448.9238

[email protected]

http://www.linkedin.com/pub/joel-mullett/3/7ab/47

COMPLIANCE AND RISK MANAGEMENT EXECUTIVE Fifteen-year compliance and risk management expert with

record of progressive responsibility and significant

achievement in development of standardized internal

control functions in broker/dealers, private banks,

international and domestic trust and wealth structuring

businesses, insurance companies, and other businesses in a

global enterprise.

Innovator in the field of anti-money laundering and

economic sanctions, responsible for delivering “best-in-

class” processes to identify and manage risk at a divisional

and enterprise level.

Global experience and industry-wide connections;

responsibility for managing audit and regulatory

relationships and exams globally with expertise in

regulatory regimes and recent developments in U.S., Asia

& Pacific Rim (India, Singapore, Japan, China, Indonesia,

Korea, Australia), Europe (U.K., Switzerland, Monaco, Italy,

Russia, France) and Latin America (Panama, Argentina,

Venezuela, Uruguay, Chile).

Expertise

Registration

Notary

Certifications

Directorship

Education

OCT

3/2011

JOEL R . MULLETT Certified Anti

Expertise

Registration

Notary

Certifications

Directorship

Education

CT 2006

3/2011


Expertise

Registration

Notary

Certifications

Directorship

Education

2006 -

3/2011 - 11/2011


Expertise

Registration

Certifications

Directorship

Education

- PRES

11/2011


Registration

Certifications

Directorship

Education

RESENT

11/2011


Registrations

Certifications

Directorship

ENT

11/2011

JOEL R . MULLETT Certified Anti-Money Laundering Specialist

•

•

•

•

JOEL R . MULLETT Money Laundering Specialist

Compliance and Risk Management

Private Banking (Domestic & Off

Trust and Wealth Structuring

Internal and External Exam Management

Operational Risk and Internal Controls

Private Lending & Commercial Lending

Cust

Q

F

N

A

Certified AntiFinalist

ASecretary of the Executive Board of Directors

NA.S.B.A., Cum Laude

Member of Alumni Advisory Board

Experiential Summarization/Employment History

B

ViceU.S. TRUST, BANK OF BANK OF

Director, Registered PrincipalMERRILL LYNCH, PIERC

Manage client onfunctional areas, and develop strategy and business requirements for migration of private banking, investment management, and trust platform to the Merrrelationships, have a common approach to onconsolidation of platforms and centralized technology & operations management

Developed standardized and controlled approach to customer“roles” to an account, as well as the entitlements and legal capacity a party has to an account

Responsible for endBank of America Merrill Lynch Retirement Services businesses

Rationalized all private banking forms (over 210) and developed strategy for consolidation and online electronic capture of data needed

Series 24Series 4Series 53Series 7Series 6Series 63Series 65








Cust

Qualifications

FINANCIAL

NOTARY

ASSOCIATION OF


ASSOCIATION OF

Secretary of the Executive Board of Directors

NEW

A.S.B.A., Cum Laude



BANK OF

ViceU.S. TRUST, BANK OF BANK OF














Customer Due

ualifications

INANCIAL

OTARY

SSOCIATION OF


SSOCIATION OF


EW ENGLAND

A.S.B.A., Cum Laude



ANK OF

Vice-President, Client OnU.S. TRUST, BANK OF BANK OF














omer Due

ualifications

INANCIAL

OTARY PUBLIC OF THE

SSOCIATION OF

Certified AntiFinalist (Runner

SSOCIATION OF


NGLAND

A.S.B.A., Cum Laude



ANK OF

President, Client OnU.S. TRUST, BANK OF BANK OF AMERICA






Series 24 Series 4 Series 53 Series 7 Series 6 Series 63 Series 65








omer Due Diligence &

ualifications

INANCIAL INDUSTRY

UBLIC OF THE

SSOCIATION OF

Certified Anti(Runner

SSOCIATION OF


NGLAND

A.S.B.A., Cum Laude



ANK OF AMERICA

President, Client OnU.S. TRUST, BANK OF

AMERICA













Diligence &

ualifications

NDUSTRY

UBLIC OF THE

SSOCIATION OF C

Certified Anti -Money Laundering Specialist(Runner-Up)

SSOCIATION OF CSecretary of the Executive Board of Directors

NGLAND COLLEGE

A.S.B.A., Cum Laude



MERICA

President, Client OnU.S. TRUST, BANK OF

AMERICA, N.A.


Manage client on-functional areas, and develop strategy and business requirements for migration of private banking, investment management, and trust platform to the Merrrelationships, have a common approach to onconsolidation of platforms and centralized technology & operations management




General Securities PrincipalRegistered Options Principal Municipal Securities PrincipalGeneral Securities RepresentativeInvestment Company/Variable ContractsUniform Securities AgentInvestment Adviser








Diligence &

ualifications, Certifications, Board Appointments and Education

NDUSTRY

UBLIC OF THE

CERTIFIED

Money Laundering SpecialistUp), Global Anti

CERTIFIED


OLLEGE

A.S.B.A., Cum Laude



MERICA

President, Client OnU.S. TRUST, BANK OF AMERICA PRIVATE WEAL

, N.A.

Director, Registered PrincipalMERRILL LYNCH, PIERCE, FENNER

-boarding, customer due diligence, accountfunctional areas, and develop strategy and business requirements for migration of private banking, investment management, and trust platform to the Merrrelationships, have a common approach to onconsolidation of platforms and centralized technology & operations management


Responsible for end-toBank of America Merrill Lynch Retirement Services businesses










Diligence & Risk

, Certifications, Board Appointments and Education

NDUSTRY REGULATORY

UBLIC OF THE C

ERTIFIED

Money Laundering Specialist, Global Anti

ERTIFIED


OLLEGE

A.S.B.A., Cum Laude , Business Administration with Securities & Capital Markets Concentration



MERICA CORPORATION

President, Client OnAMERICA PRIVATE WEAL

Director, Registered PrincipalE, FENNER

boarding, customer due diligence, accountfunctional areas, and develop strategy and business requirements for migration of private banking, investment management, and trust platform to the Merrrelationships, have a common approach to onconsolidation of platforms and centralized technology & operations management


to-end customer due diligence Bank of America Merrill Lynch Retirement Services businesses

Rationalized all private banking forms (over 210) and developed strategy for consolidation and online electronic capture of data needed to eliminate paper forms in target state environment









Risk


EGULATORY

COMMONWEALTH OF

ERTIFIED A


ERTIFIED ASecretary of the Executive Board of Directors

OLLEGE – B

Business Administration with Securities & Capital Markets Concentration



ORPORATION

President, Client On -Boarding, Private BankingAMERICA PRIVATE WEAL

Director, Registered PrincipalE, FENNER



end customer due diligence Bank of America Merrill Lynch Retirement Services businesses

Rationalized all private banking forms (over 210) and developed strategy for consolidation and online electronic to eliminate paper forms in target state environment




Private Banking (Domestic & Off-shore)




Risk Mgmt.


EGULATORY

OMMONWEALTH OF

ANTI


ANTI


BUSINESS




ORPORATION

Boarding, Private BankingAMERICA PRIVATE WEAL

Director, Registered PrincipalE, FENNER & SMITH INCORPORATED






JOEL R . MULLETT Money Laundering Specialist™

shore)




Mgmt.


EGULATORY

OMMONWEALTH OF

NTI-M

Money Laundering Specialist, Global Anti-Money Laundering Professional of the Year Award™ 2009

NTI-MSecretary of the Executive Board of Directors

USINESS



ORPORATION


Director, Registered Principal & SMITH INCORPORATED






JOEL R . MULLETT ™

shore)




EGULATORY AUTHORITY AND

OMMONWEALTH OF

MONEY

Money Laundering SpecialistMoney Laundering Professional of the Year Award™ 2009

MONEY


USINESS



ORPORATION


& SMITH INCORPORATED





General Securities PrincipalRegistered Options Principal Municipal Securities PrincipalGeneral Securities RepresentativeInvestment Company/Variable ContractsUniform Securities Agent

JOEL R . MULLETT

Anti

Brokers and Dealers of Securities (SEC Registered and International)

Investment Companies, Investment Advisory, and Family Offices

Regulatory Rel

Supervisory Co

Extensive Global Experience in Europe, Asia and Pacific Rim, Latin America

Reporting and Executive Management Committee Structures/Risk Disposition


UTHORITY AND

OMMONWEALTH OF

ONEY L


ONEY LSecretary of the Executive Board of Directors

USINESS & F



ORPORATION

Boarding, Private BankingAMERICA PRIVATE WEALTH MANAGEMENT •






General Securities Principal Registered Options Principal Municipal Securities Principal General Securities RepresentativeInvestment Company/Variable Contracts

Anti-Money Laundering & Economic Sanctions (OFAC, etc.)



Regulatory Rel

Supervisory Co




UTHORITY AND

OMMONWEALTH OF

LAUNDERING


LAUNDERING


FINANCE



Boarding, Private BankingTH MANAGEMENT •


boarding, customer due diligence, accountfunctional areas, and develop strategy and business requirements for migration of private banking, investment management, and trust platform to the Merrill Lynch platform as part of a major initiative to segment customer relationships, have a common approach to onconsolidation of platforms and centralized technology & operations management




General Securities RepresentativeInvestment Company/Variable Contracts

Money Laundering & Economic Sanctions (OFAC, etc.)



Regulatory Rel

Supervisory Co




UTHORITY AND

OMMONWEALTH OF MASSACHUSETTS

AUNDERING

Money Laundering Specialist ® Money Laundering Professional of the Year Award™ 2009

AUNDERING


INANCE





boarding, customer due diligence, accountfunctional areas, and develop strategy and business requirements for migration of private banking, investment

ill Lynch platform as part of a major initiative to segment customer relationships, have a common approach to on-boarding and client data management, and gain cost saves through consolidation of platforms and centralized technology & operations management




General Securities Representative Investment Company/Variable Contracts




Regulatory Relations and Policy Development

Supervisory Control Systems, Tools, Functions, Project/Program Mgmt




UTHORITY AND S

ASSACHUSETTS

AUNDERING

Money Laundering Professional of the Year Award™ 2009

AUNDERING

Secretary of the Executive Board of Directors , 2009 to Present

INANCE






ill Lynch platform as part of a major initiative to segment customer boarding and client data management, and gain cost saves through

consolidation of platforms and centralized technology & operations management


end customer due diligence experience for U.S. Trust, Merrill Lynch Trust Company, and Bank of America Merrill Lynch Retirement Services businesses


Investment Company/Variable Contracts




ations and Policy Development

ntrol Systems, Tools, Functions, Project/Program Mgmt




SELF

ASSACHUSETTS

AUNDERING S


AUNDERING S2009 to Present









experience for U.S. Trust, Merrill Lynch Trust Company, and Bank of America Merrill Lynch Retirement Services businesses










ELF- R

ASSACHUSETTS

SPECIALISTS


SPECIALISTS

2009 to Present



Boarding, Private Banking Office of Business TransformationTH MANAGEMENT • MERRILL LYNCH TRUST







American Stock Exchange, LLC (NYSE AMEX EquitiesChicago Board Options Exchange, Incorporated International Securities Exchange Holdings, Inc. NASDAQ Stock MarketNASDAQ OMX PHLX, Inc. (PhiladelpNew York Stock ExchangeNYSE Arca, Inc.









REGULATORY

ASSACHUSETTS

PECIALISTS


PECIALISTS

2009 to Present



Office of Business TransformationMERRILL LYNCH TRUST

boarding, customer due diligence, account-open, accountfunctional areas, and develop strategy and business requirements for migration of private banking, investment



Developed standardized and controlled approach to customer-“roles” to an account, as well as the entitlements and legal capacity a party has to an account












EGULATORY

ASSACHUSETTS

PECIALISTS


PECIALISTS

2009 to Present




open, accountfunctional areas, and develop strategy and business requirements for migration of private banking, investment



-to-account relationships and defined the types of “roles” to an account, as well as the entitlements and legal capacity a party has to an account












EGULATORY

PECIALISTS ™


PECIALISTS ™2009 to Present






account relationships and defined the types of “roles” to an account, as well as the entitlements and legal capacity a party has to an account

experience for U.S. Trust, Merrill Lynch Trust Company, and











EGULATORY O

™ (ACAMS)


™ (ACAMS)


















ORGANIZATION

(ACAMS)


(ACAMS)



open, account-functional areas, and develop strategy and business requirements for migration of private banking, investment






American Stock Exchange, LLC (NYSE AMEX EquitiesChicago Board Options Exchange, Incorporated International Securities Exchange Holdings, Inc. NASDAQ Stock MarketNASDAQ OMX PHLX, Inc. (PhiladelpNew York Stock Exchange









RGANIZATION

(ACAMS)


(ACAMS)


Office of Business TransformationMERRILL LYNCH TRUST COMPANY

-maintenance, and accountfunctional areas, and develop strategy and business requirements for migration of private banking, investment





Rationalized all private banking forms (over 210) and developed strategy for consolidation and online electronic

American Stock Exchange, LLC (NYSE AMEX EquitiesChicago Board Options Exchange, Incorporated International Securities Exchange Holdings, Inc. NASDAQ Stock Market NASDAQ OMX PHLX, Inc. (PhiladelpNew York Stock Exchange








RGANIZATION

(ACAMS)


(ACAMS) –


Office of Business TransformationCOMPANY

maintenance, and accountfunctional areas, and develop strategy and business requirements for migration of private banking, investment






American Stock Exchange, LLC (NYSE AMEX EquitiesChicago Board Options Exchange, Incorporated International Securities Exchange Holdings, Inc.

NASDAQ OMX PHLX, Inc. (PhiladelpNew York Stock Exchange








RGANIZATION


– BOSTON


Office of Business TransformationCOMPANY







NASDAQ OMX PHLX, Inc. (Philadelp

[email protected]







RGANIZATION REGISTRATIONS


OSTON


Office of Business TransformationCOMPANY • RETIREMENT SERVICES







NASDAQ OMX PHLX, Inc. (Philadelphia Stock Exchange)

36 A Street Unit 2C

[email protected]

Money Laundering & Economic Sanctions (OFAC, etc.) Brokers and Dealers of Securities (SEC Registered and International)





EGISTRATIONS


OSTON C

Office of Business TransformationRETIREMENT SERVICES







hia Stock Exchange)

36 A Street Unit 2CBoston, MA 02127

[email protected]






EGISTRATIONS

CHAPTER

Office of Business Transformation RETIREMENT SERVICES







hia Stock Exchange)


[email protected]





EGISTRATIONS

HAPTER

RETIREMENT SERVICES



account relationships and defined the types of




hia Stock Exchange)


[email protected]




EGISTRATIONS

HAPTER

RETIREMENT SERVICES

maintenance, and account-functional areas, and develop strategy and business requirements for migration of private banking, investment





American Stock Exchange, LLC (NYSE AMEX Equities Chicago Board Options Exchange, Incorporated

hia Stock Exchange)


[email protected]



RETIREMENT SERVICES

-close functional areas, and develop strategy and business requirements for migration of private banking, investment





hia Stock Exchange)


[email protected]


RETIREMENT SERVICES

close functional areas, and develop strategy and business requirements for migration of private banking, investment





hia Stock Exchange)


[email protected]

functional areas, and develop strategy and business requirements for migration of private banking, investment

boarding and client data management, and gain cost saves through




36 A Street Unit 2C Boston, MA 02127

617.448.9238 [email protected]

boarding and client data management, and gain cost saves through

BANK OF AMERICA CORPORATION (CONTINUED FROM PREVIOUS PAGE)

12/2009 - 3/2011 Director, Chief Anti-Money Laundering Risk Officer for the Americas & Registered Principal

MERRILL LYNCH WEALTH MANAGEMENT, MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED

Director, Executive Officer, and Chief Anti-Money La undering Compliance Officer GPC SECURITIES INCORPORATED

Vice-President, Division Senior Anti-Money Launderi ng Risk Manager BANK OF AMERICA, N.A. GLOBAL ANTI-MONEY LAUNDERING AND ECONOMIC SANCTIONS

• Head of AML risk management for Merrill Lynch Wealth Management businesses in the Americas (U.S., Latin America, and the Caribbean): U.S. WEALTH MANAGEMENT & LATIN AMERICA INTERNATIONAL MONEY MANAGER SERVICES (RIA PLATFORM)

PRIVATE BANKING & INVESTMENT GROUP BOFA™ GLOBAL CAPITAL MANAGEMENT

MERRILL SIGNATURE CARDS AND CUSTOMIZED CREDIT

ALTERNATIVE INVESTMENTS (PRIVATE EQUITY, HEDGE FUNDS, V.C.)

FINANCIAL DATA SERVICES INCORPORATED (TRANSFER AGENT)

MERRILL LYNCH HOME LOANS

• Manage implementation of the Anti-Money Laundering and Economic Sanctions Programs required by enterprise policy

• Provide risk management and subject matter expertise on money laundering, terrorist financing, financial crime and economic sanctions issues to the executive, divisional, and regional management of Merrill Lynch Wealth Management

• Partner with executive management, compliance, risk, legal, governance and control, and audit partners to ensure an effective internal control environment and governance process

• Direct assessment of the risk posed by money laundering, terrorist financing, financial crimes and economic sanctions, and document action plans with recommendations for closing gaps and enhancing internal controls

• Supervise investigations matters for Merrill Lynch Wealth Management originating from monitoring, surveillance to ensure quality of analysis, proper disclosure to government authorities where appropriate, and advise in disposition of continued business relationship with customers subject to investigation/concerns

• Supervise the processes and functions related to screening of customers and transactions for economic sanctions purposes and escalate matters to the Economic Sanctions Executive where appropriate

• Ownership of Merrill Lynch Wealth Management-specific AML, economic sanctions, and customer due diligence training; set the tone for priority of AML and economic sanctions program with executive management and raise awareness throughout the division

10/2006 – 12/2009 Vice-President, Global Head of Customer Due Diligen ce and Risk Management

BANK OF AMERICA GLOBAL WEALTH & INVESTMENT MANAGEMENT (U.S. TRUST, BANC OF AMERICA INVESTMENT SERVICES, INC., COLUMBIA MANAGEMENT, AND PREMIER BANKING & INVESTMENTS) COMPLIANCE & RISK MANAGEMENT

• Responsible for end-to-end customer due diligence (Know Your Customer) process, systems and technology, functional areas, quality control, audit and exam management, training, and reporting to executive management

• Developed a process and approach for identification and management of high risk customer base using internal risk definitions, outside sources for scanning against negative media, etc., and provided comprehensive reporting to enable executive management to be articulate about the inherent risk present in its portfolio

• Direct recommendations to executive management on mitigation of risk, including termination (where appropriate) of customer relationships based upon money laundering, terrorist financing, financial crime, and economic sanctions, reputational risk

• Manage teams dedicated to on-boarding and monitoring of high risk customers, support on-boarding process, controls, risk assessment, enhanced due diligence functions, vendor selection/customization, and central management of negative events

• Manage internal and external audit and exams (OCC, SEC, FINRA, Federal Reserve, independent consultants, corporate audit)

• Manage multi-year, multi-million dollar project management office to execute global standardization of customer due diligence at on-boarding; establish governance routines with regional AML risk managers globally as the customer due diligence practice lead

• Manage end-to-end U.S. Trust, LaSalle, Countrywide, and Merrill Lynch transition projects for AML

7/2005 – 10/2006 J.P. MORGAN CHASE & CO. INCORPORATED • OFFICE OF THE GENERAL COUNSEL

Vice President | Senior Compliance Officer, Asset & Wealth Management Compliance JPMORGANCHASE BANK, N.A.

Chief Compliance Officer, Compliance Registered Opt ions Principal, Executive Officer JPMORGAN INVEST Online Brokerage, J.P. MORGAN INSTITUTIONAL INVESTMENTS INC.

• Chief Compliance Officer, JPMorgan Invest, the self-directed brokerage offering of JPMorgan Asset & Wealth Management

J.P. MORGAN CHASE & CO. INCORPORATED (CONTINUED FROM PREVIOUS PAGE)

• Executive Officer of J.P. Morgan Institutional Investments Inc. and Compliance Registered Options Principal, responsible for execution of the compliance program within self-directed brokerage business;

• Supported transition of BrownCo LLC (brokerage) to E*TRADE, including compliance support and conversion of accounts

• Managed review, approval, and records for all communications of the firm to ensure compliance with NASD, SEC, ERISA, and firm standards;

• Compliance oversight of retail and institutional product management for wide range of offerings, including online brokerage ; mutual funds; equities; options; fixed income; health savings accounts; private equity; alternative investments; employee retirement plans; research and advice

• Compliance Registered Options Principal (CROP) for broker/dealer: responsible for compliance with federal securities laws and self-regulatory organization rules, set policy and govern compliance program for option activities; provide final review and approval of options-related advertisements/communications; testing of policies and procedures; quarterly review of options business for reporting to CEO

• Support middle and back office operations functions; manage exception reporting, including aggregate B-share purchases, options activity, mutual fund switches, breakpoint reports, etc.; maintained books and records and ensured line supervision review as necessary; reviewed best execution reports

• Perform annual audits of corporate broker/dealer offices of supervisory jurisdiction (OSJs)

• Managed firm customer complaint and regulatory inquiry procedures and responses

04/2000 – 07/2005 METLIFE, INC. • CORPORATE ETHICS AND COMPLIANCE

Compliance Director METROPOLITAN LIFE INSURANCE COMPANY, METLIFE SECURITIES INC. (METLIFE BROKER/DEALER GROUP)

• Managed corporate sales material review and investment advisory compliance functions for MetLife corporate communications and all individual lines of business

• Responsible for registered principal review of corporate-produced advertising, sales literature, and other materials as defined by firm policy for four dually-registered broker/dealers and investment advisers, in addition to its life, disability, and long term care insurance issuers. Ensured compliance with FINRA, SEC, NAIC, state regulations and company policies

• Directed project management office set up for transformation of corporate approach to communications, leading development of web-based application to facilitate sales material review and creation of enterprise level program

• Director of investment adviser compliance for corporate and third party registered investment adviser products and services for all MetLife broker/dealer and individual lines of business

• Managed regulatory examinations, inquiries, and registration of the broker/dealer and investment adviser affiliates of MetLife

• Directed compliance review functions for new product development for all MetLife broker/dealer and investment adviser affiliates

1999-2000 EDWARD JONES INVESTMENTS LP • PRODUCT & SALES

Trader – Listed Equities EDWARD JONES TRADE OPERATIONS

• Traded exchange listed equity and other general securities; monitored trades and open orders for best execution; reviewed time & sales reports for quality control; billed customer trades and executed trade corrections (incorrect securities, cancels, buy v. sell, price corrections); directed order flow to various exchanges or market centers during system outages; negotiated price improvement with Pershing floor brokers; directed orders to specific market center at customer request

1996-1999 DEUTSCHE BANK A.G. • DEUTSCHE BANK ASSET MANAGEMENT/DWS INVESTMENTS

Quality Assurance Supervisor DWS SCUDDER DISTRIBUTORS INC.

• Evaluate recorded phone calls in Shareholder Services and Sales Support, then provide feedback on how to make calls more proactive and raise service levels and uncover new sales opportunities for mutual fund arm; ensured quality of transaction processing, problem research and resolution, and client service

Mullett joel r cv 2011 compliance and risk management executive

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