[Webinar] Navigating the New Investment Adviser AML Mandate: What Steps Should Investment Advisers Be Taking Now?

January 15th, 9:30 am PT
K2 Integrity
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K2 Integrity

January 15th, 2025
9:30 AM PT

Investment advisers and others involved in the implementation of the new IA AML mandate have been alert to potential ramifications to the rule due to the upcoming change in administration. Upon review, K2 Integrity and industry experts do not anticipate the final rule to be affected by the new administration; therefore, IAs should be acting now to be in full compliance by 1 January 2026. Join us for a discussion of the complexities of the IA BSA/AML Rule and what steps firms should be undertaking, including discussion on:

  • The underlying complexities of the rule – broader than KYC
  • Understanding key inherent AML risks
  • The importance of establishing an appropriate timeline for implementation
  • What to expect in the examination process
  • The implications for noncompliance

Join our panel of experts for a one-hour session where they will discuss implications for policies, procedures, and controls; governance and operational processes; third-party contractual arrangements; and other matters. You’ll hear from Justina Rousseau, senior managing director at K2 Integrity; Aseel Rabie, counsel at Debevoise & Plimpton LLP; and moderator Sarah Runge, executive managing director at K2 Integrity.

Speakers

Aseel Rabie

Counsel·Debevoise & Plimpton LLP

Aseel Rabie is a member of the firm’s Banking Group and Financial Institutions Group.

Ms. Rabie’s practice focuses on advising clients on a broad range of regulatory, supervisory and enforcement matters in the anti-money laundering and sanctions space. She also provides counsel on matters involving financial crimes in the context of transactions, fundraising, lending and investigations.

Prior to joining the firm, Ms. Rabie served as a managing director and associate general counsel at the Securities Industry and Financial Markets Association (SIFMA) where she was responsible for regulatory advocacy and other activities in the anti-money laundering, sanctions and other financial crime compliance areas, as well as primary capital markets and research.

Before her role at SIFMA, Ms. Rabie served as senior counsel in the Securities and Exchange Commission’s Office of the General Counsel. There, she advised on legal and policy matters relating to SEC rulemaking activities and enforcement actions. Previously in her career, Ms. Rabie served as the lead in-house counsel on corporate finance and securities law matters at a satellite communications company and worked on securities regulatory and enforcement, anti-corruption and other matters in private practice.

Ms. Rabie received her B.A. cum laude from Harvard College and her J.D. cum laude from Harvard Law School.

Justina Rousseau

Senior managing director·K2 Integrity

Justina Rousseau is a trusted advisor and financial crimes thought leader with over two decades of experience building programs designed to detect and prevent risk at first, second, and third line of defense roles. With extensive knowledge of U.S. and international financial crimes compliance, including Bank Secrecy Act/Anti Money Laundering (BSA/AML) regulations, she works with investment advisors and financial institutions to design, develop, and implement compliance programs in line with requirements issued by the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) and other regulators. Justina aids clients in recognizing problem areas and make appropriate risk-based decisions, and assists them with program management; remedial action management; development, implementation, and execution of procedures; identification of control weaknesses; and continual process improvements.

Prior to joining K2 Integrity, Justina held senior leadership positions at IBM’s Promontory Financial Group, most recently as deputy head of Americas and head of the Americas Financial Crimes Risk Management Advisory practice group. In those roles, she worked with large financial services institutions focusing on regulatory compliance, financial crime prevention, and risk management, giving her a deep understanding of the challenges facing internal regulatory compliance teams and the support they require from outside advisors. Justina advised financial institutions and regulators on all aspects of enforcement, regulation, and compliance or operational risk issues.

Before joining Promontory, Justina was an executive vice president at Wells Fargo Bank, where she held several key financial crime roles within the financial crime audit division and first line of defense roles within commercial banking and global financial institutions. She began her career at U.S. Bancorp.

Sarah Runge

Executive Managing Director – Financial Crimes Compliance·K2 Integrity

Sarah Runge is an executive managing director at K2 Integrity. She boasts a wealth of experience in anti-money laundering and countering the financing of terrorism (AML/CFT) regimes in the public and private sectors.

Before 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 that managed the global compliance program for all regulated products globally. Before her time at Meta, Sarah was the global head of FCC regulatory strategy for at Credit Suisse, where she developed and managed a global risk management strategy to mitigate regulatory risk. This work included leading remediation of deficiencies of 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. Her team developed domestic and international strategies to address illicit finance through work with supervisors, law enforcement, and policy makers in the United States and globally. Sarah Runge served as the head of the U.S. delegation to FATF from 2017 to 2018, when she was also a member of the FATF Steering Group. Sarah was a senior member of the U.S. delegation to FATF from 2011 to 2017, including as the lead negotiator on the changes to the FATF standards on beneficial ownership, correspondent banking, cross-border information sharing, and nonprofit organizations.

Sarah earned an M.A. in international affairs from the Johns Hopkins School of Advanced International Studies (SAIS) and a B.A. in history from Scripps College.

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