Laura Brunelli
Charlotte
Summary
Experienced and driven Financial Crimes Executive Director with a background in BSA/AML, Sanctions, ABC, Risk Assessment, Controls, Regulatory Execution, and various other aspects of financial crimes. Demonstrates exceptional project management skills and an ability to adapt to leadership changes, ensuring high-quality deliverables under enhanced oversight and tight scrutiny. Expert in stakeholder collaboration and maintaining a positive outlook in fast-paced environments. Select career highlights include managing all Controls, testing, exams, Issues and Corrective Actions for the Wells Fargo Financial Crimes Risk Assessment Program and partnering with senior leadership on the development of strategic action plans to enhance the governance process for Targeted Risk Assessment and Enterprise-Wide Risk Assessment.
Overview
14
14
years of professional experience
1
1
Certification
Work History
Executive Director - FCRM Risk Assessment
Wells Fargo Bank, N.A.
05.2023 - Current
- Led and organized all communications and requests for information from internal and external exam and testing engagements related to FCRM Risk Assessment (RA)(including but not limited to: Audit, Independent Testing, Controls teams, Regulators), as well as compiled all artifacts and documentation for RA Issues and Corrective Actions
- Coordinated communication between third party vendor and risk assessment stakeholders in the execution of a comprehensive overhaul of the Financial Crimes Enterprise-Wide Risk Assessment (EWRA) Methodology, development of a new procedure aligned to the methodology, and integration of a vendor supported risk assessment solution on a consolidated timeline (28-month timeline for 8-month delivery)
- Spearheaded the development of a net new BSA/AML and Sanctions Targeted Risk Assessment process which includes all required governance documentation, controls, internal training needs for key stakeholders, and senior leadership/management committee reporting templates once implemented (expected initial execution in April 2025)
- Guided risk assessment staff and business group and second line RA stakeholders through period of substantial organization change, maintaining overall morale and engagement during transitions (e.g., move the line exercise, 4 separate leadership changes in less than 18 months)
- Partnered closely with senior leadership in several groups (e.g., Regulatory Execution, Audit, Risk Transformation, Legal, Financial Crimes, Vendor) and contributed to the development of the BSA/AML and Sanctions Risk Assessment Action Plan/submission in response to the Wells Fargo Formal Agreement (publicly available information)
- Assisted in the execution of the 2023 and 2024 Enterprise-Wide Risk Assessments to determine the quantitative and qualitative (inherent) risk of assessment units and business groups and evaluation of the controls and risk mitigation measures to derive the overall residual risk. Developed the overall annual EWRA report and executive level summary for senior leadership presentation to necessary bank committees and the Risk Committee of the Board.
VP of BSA/AML Compliance
Start-Up Retail Bank
11.2022 - 04.2023
- Engaged with very high risk and unique customer relationships, including digital assets and Cannabis Related Businesses (CRB) to assist with Customer Identification Program (CIP) and Customer Due Diligence (CDD) requirements
• Partnered with Subject Matter Experts (SME) in various industries to conduct Enhanced Due Diligence (EDD) reviews for high-risk customers (including but
not limited to digital assets, CRB, International Customers, Correspondent Banking, etc.) to determine if the relationships were aligned with Bank’s risk appetite and should have been onboarded based on internal policies and procedures
• Established and enhanced internal governance documentation related to compliance/BSA/AML policies and procedures
• Assisted with requests from Law Enforcement, external audit, and regulators and completed issue follow-up and remediation in a timely fashion
• Produced periodic updates/reporting to the Chief Risk Officer and Head of Financial Crimes on the status of the implementation of the compliance/BSA program, as well as the timeliness of onboarding customers/businesses of different risk ratings
• Managed transaction alerts, worked investigations, and filed Suspicious Activity Reports (SAR) for Bank’s
customers/relationships
Vice President - Lead Financial Crimes Officer
Wells Fargo Advisors
01.2022 - 11.2022
- Oversaw and trained additional team members in their review of cases within the designed Quality Assurance (QA) program over Brokerage Specific Financial Crimes teams using self-created training guides, as well as provided feedback and coaching in the implemented processes
- Collaborated with Financial Crimes Analytics Monitoring and Surveillance (FCAMS) team to create efficiencies in data pulling for WFCS and FINET financial crimes to be used over the QA Procedure
- Initiated reviews of UARs submitted by internal monitoring teams (Elder Client Initiatives, High Risk Monitoring, Wealth Investment Management) to enhance the information provided to Financial Crimes Investigations to assist in accurate case determinations and SAR Information
- Supported Wells Fargo Securities in ad hoc projects pertaining to system parameters including review of risk associated to the timeframe for alerts in Trading Ahead of Market Events (TAME)
- Centralized Report Reviews pertaining to SAR, alert, case and exit recommendation data received by data analytics teams to help highlight trends and escalation points to present to the WFCS/FINET BSA Officer
AVP - Compliance Senior Associate
Wells Fargo Advisors
09.2019 - 01.2022
- Assisted in the design, creation, and implementation of a new Quality Assurance program over the Financial Crimes Investigations Brokerage Investigations Group (BIG) to review and assess AML cases
- Generated QA reports that were shared internally with the Brokerage Investigations Group, as well as presented monthly to the WFCS AML Officer and Brokerage management to discuss QA trends, areas of inconsistencies, and recommend improvements to BIG investigative steps
- Developed and prepared an “in-solution” report function within Financial Crimes Platform (FCP) that enabled the team to independently obtain monthly population of closed AML investigations, which was the foundation of the QA process
- Assumed responsibility for the due diligence oversight of Canadian Marijuana Related Business (MRB) security trading by partnering with the Trading area to ensure that the operating practices were consistent with the Wells Fargo Compliance Program, policies, operating procedures, and legal and regulatory requirements
- Managed the Marijuana Related Business determinations and due diligence processes and collaborated with impacted stakeholders to ensure that there customers met both Wells Fargo corporate policy requirements and the risk tolerance of WFCS's compliance risk management program
Senior Investigator - Brokerage AML Investigations
Wells Fargo Advisors
06.2016 - 09.2019
- Acted as Interim Manager to a team of 9 due to Manager being on leave. Duties included: organizing team meetings, providing coaching and feedback for investigators on cases assignments, assisting in the hiring and training of new team members, working directly with Senior Management on the implementation of new policies and procedures
- Approved cases submitted by investigators and ensured all necessary clients and accounts were reviewed appropriately in compliance with internal policies, procedures, and guidelines
- Analyzed trading and securities activity to identify the purchase or sale of low-priced securities for indications of insider trading and various other market manipulation strategies conducted by the clients
- Reviewed Enhanced Due Diligence documents for high-risk clients (private banking, PEPs, international, confidential customers, etc.) to determine if transactions appear consistent with the intended use of the accounts according to CDD and EDD paperwork
- Coordinated and led special projects to supply information and supporting documentation related to Internal Investigations, as well as SEC/FINRA/OCC audits and addressed outstanding issues, as needed
Financial Crimes Investigator
Wells Fargo Bank, N.A.
06.2014 - 06.2016
- Responsible for identifying and researching the patterns, trends, and anomalies in complex transactional data to detect, prevent, mitigate, and filed SARs related to AML, BSA, TF, fraud, and structuring
- Recommended exiting customer relationships (RECRs/EFEs) from Wells Fargo based on Regulatory or Reputational risks to the bank due to significant SAR filings or known connection to illicit activity
- Requested information from other financial institutions through 314(b) of the USA PATRIOT Act Sharing of Information requests
- Reviewed Grand Jury Subpoenas (GJS) and National Security Letters (NSLs) attached to investigations to assess the risk of customers and help with appropriate SAR filings
Fraud Detection and Investigation Unit
Liberty Mutual Group
01.2011 - 04.2014
Education
Bachelor of Science - Criminal Justice, Minor in Business Administration
Northeastern University
Boston, MASkills
- Ability to manage several different workstreams, identify key issues while recommending proposed solutions, collaborate with various different groups of stakeholders and maintain a positive attitude while working in a face-paced environment with a substantial amount of oversight/scrutiny
- Highly efficient time management skills in dealing with completing priorities for numerous critical deliverables
- Excellent oral, written, and interpersonal communication skills
- Advanced project management and strategic execution and development skills through the creation of action plans and work with third party vendor engagements
- Ability to accept and adapt to leadership and organizational changes while maintaining refined and polish work product
Certification
- Certified Anti-Money Laundering Specialist (CAMS)
Timeline
Executive Director - FCRM Risk Assessment
Wells Fargo Bank, N.A.
05.2023 - Current
VP of BSA/AML Compliance
Start-Up Retail Bank
11.2022 - 04.2023
Vice President - Lead Financial Crimes Officer
Wells Fargo Advisors
01.2022 - 11.2022
AVP - Compliance Senior Associate
Wells Fargo Advisors
09.2019 - 01.2022
Senior Investigator - Brokerage AML Investigations
Wells Fargo Advisors
06.2016 - 09.2019
Financial Crimes Investigator
Wells Fargo Bank, N.A.
06.2014 - 06.2016
Fraud Detection and Investigation Unit
Liberty Mutual Group
01.2011 - 04.2014
Bachelor of Science - Criminal Justice, Minor in Business Administration
Northeastern University
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