OFAC Sanctions Expert Witness | United States Sanctions Expert Witness

Stephanie held senior financial crimes compliance roles with several large, global financial institutions including JPMorgan Chase, Commerzbank, and Bank of Tokyo Mitsubishi. Prior to working in the private sector, Stephanie served as an Investigator with the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC). In this role, Stephanie worked on large multi-agency investigations involving sanctions evasion networks, terrorism financing, organized crime, and money laundering; and brought enforcement actions against banks, exporters, technology companies, and transportation companies for sanctions misconduct. 

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Stephanie also provided training to prosecutors, foreign delegations, and industry groups on U.S. sanctions regulations and enforcement. Stephanie holds a BA from the George Washington University where she graduated from the University Honors Program with a double-major in Middle East Studies and Conflict & Security Studies, and a minor in Arabic. She has lived abroad in Germany, Lebanon, and Hong Kong and speaks German, Arabic, and English.

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Professional Experience

  

• ​Bank of Tokyo-Mitsubishi UFJ, Ltd. - Director, Head of U.S. Sanctions Compliance (2017 - 2018)

  • Served as U.S. Sanctions Head and one of two appointed OFAC officers for the firm

  • Supervised all aspects of sanctions compliance for BTMU U.S. entities including screening,
    escalations, advisory, policies/procedures, program development, regulatory exams,
    investigations, and reporting

  • Advised global offices on OFAC related investigations, escalations, and other advisory
    matters

  • Managed team of 15+ employees, including sanctions officers, investigators, and analysts​​

  

• Commerzbank AG New York - Director, Head of Sanctions Compliance (2015 – 2017)​

  • Served as regional Sanctions Head for the New York branch, and OFAC officer for the firm

  • Supervised all aspects of sanctions compliance including sanctions screening, payment
    escalations, advisory, policies/procedures, training, license applications, investigations, and
    reporting

  • Advised Global Sanctions team in Frankfurt on all OFAC-related matters

  • Managed team of five sanctions officers and analysts

  

• JPMorgan Chase & Co., Global Financial Crimes Compliance - Vice President, Financial Crimes Compliance Manager  (2012 - 2015)​​

  • Served as one of two advisors on the Global Sanctions Compliance Advise & Consult team​

  • Advised on sanctions escalations originating from all lines of business and regions across
    the firm; supervised mandatory reporting and policy/procedure writing; submitted license
    applications for the firm; provided training to regional and product sanctions officers and
    the business; and supported client outreach

  • Assigned to Hong Kong for 3 months to train and support the APAC regional financial
    crimes compliance team, as well as to providing financial crimes training to various
    business units and correspondent banking clients within the region

  

• U.S. Dept. of the Treasury, Office of Foreign Assets Control - Sanctions Enforcement Investigator (GS 13) (2007 - 2012) 

  • Initiated and conducted investigations and brought enforcement actions against banks,
    exporters, technology companies, and transportation companies for sanctions misconduct​​

  • Worked on large multi-agency investigations involving sanctions evasion networks,
    terrorism financing, and money laundering

  • Provided sanctions training to law enforcement, foreign delegations, and industry
    associations

  • Recipient of three Special Act Awards for personal contribution to the mission of the agency

  

• Williams Mullen Strategies - Research Analyst (2006 - 2007)

  • Conducted research on energy and foreign policy matters​

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• Department of the Army, Office of Chief Legislative Liaison - Intern (2005 - 2006)

  • Assisted in organizing Congressional Delegations and conducted investigations pursuant to
    Congressional inquiries

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• C4ADS (Center for Advanced Defense Studies) - Intern Analyst (2005)

  • Prepared analysis and reporting on counterproliferation, organized crime, and
    environmental crime

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Education

 

• The George Washington University, Washington, DC, 2008
  Elliott School of International Affairs/University Honors Program, BA, suma cum laude

  • Degree Major: International Political Economics; Minor: Arabic

  • Recipient of Edward Gnehm Honors Scholarship for Arabic Language Studies

  

• Georgetown University, Washington, DC, 2007

  • Intensive Summer Language Institute for Arabic Study

  • Completed coursework in Levantine Arabic and Advanced Modern Standard Arabic

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• American University of Beirut, Lebanon, 2006

  • Completed Arabic coursework and graduate coursework in Middle East political science
    studies

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• Universität Augsburg, Germany, 2004

  • Advanced German summer program

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Languages

   

• German (Native Speaker), Arabic (Advanced), Farsi (Elementary)​

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 Training

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• ACAMS Certification, 2011

• Letters of Credit and Trade Finance, U.S. Treasury Dept., 2010

• Proliferation Networks and Financing, government agency, 2010

• Economic Sanctions, government agency, 2010

• Arabic and Farsi language courses, Middle East Institute, 2009-2012

• Underground Economies, government agency, 2009

• Islamic Banking, government agency, 2009

• World Oil Markets, government agency, 2009

• International Banking Operations, government agency, 2009

• Criminal Investigator Training Program, Federal Law Enforcement Training Center, 2009

• Banking & Money Laundering, Federal Law Enforcement Training Center, 2008