Ross Delston - CAMS
Senior Compliance Consultant

WORK EXPERIENCE

GLOBALAML.COM, WASHINGTON, DC
November 2006 – present, Principal

  • Founded consulting firm specializing in anti-money laundering and combating the financing of terrorism (AML/CFT) compliance for financial institutions.
  • Speaker and moderator at conferences and seminars around the world on AML/CFT compliance and banking issues (see page 4 for details).
  • Consultant to IMF on AML/CFT and banking issues (see below for details).

Through his firm GlobalAML.Com, Ross Delston is a Senior Compliance Consultant with Bekker Compliance Consulting Partners, LLC (BCCP) and provides regulatory compliance consulting services to BCCP’s financial services clientele.

KALORAMA PARTNERS, WASHINGTON, DC
October 2005 – October 2006, Managing Director

  • Advised financial institutions on AML/CFT compliance issues as a member of strategic consulting firm headed by former SEC Chairman Harvey Pitt.
  • Consultant to firm on review of compliance program for broker-dealer to ensure consistency with NYSE and FINRA requirements, October 2005.

LEGAL DEPARTMENT, INTERNATIONAL MONETARY FUND,
WASHINGTON, DC

August 2000 – September 2005, Consulting Counsel, specializing in AML/CFT

September 1997 – July 2000, Legal Consultant (occasional basis), specializing in banking and central bank law

  • AML/CFT Assessments: Participated in seven Offshore Financial Center assessments: Aruba, Gibraltar, Guernsey, Isle of Man, Jersey, the Netherlands Antilles and Panama. The assessments rated compliance by jurisdictions with FATF 40+9 Recommendations based on a two-week visit by a team of experts.
  • AML/CFT Legislation: Chaired working group to draft model AML/CFT law for common law countries. Legislative drafting missions to Austria to meet with Afghan officials, Belarus twice), Philippines, and Sri Lanka (twice). Reviewed and commented on numerous legislative proposals for CIS, Asian and African countries.
  • AML/CFT Technical Assistance Coordinator, January 2003 – September 2004. Assigned projects, mainly legislative drafting and financial intelligence unit issues. Designated by General Counsel to coordinate Legal Department activities during initial phase of Offshore Financial Center program, August 2000 – January 2001.
  • Banking Legislation: Participated in missions to draft banking, bank restructuring, central banking, and deposit insurance laws in: Azerbaijan, Croatia, Indonesia (during financial crisis), the Philippines, and Russia (during financial crisis); reviewed and drafted legislative proposals for numerous countries including Iraq in 2003.
  • AML/CFT and Banking Training: Frequent speaker, commentator and organizer in connection with conferences and seminars around the world (see page 4, below).

LEGAL DEPARTMENT, THE WORLD BANK, WASHINGTON, DC
1998 – 2001, Legal Consultant (occasional basis), specializing in banking law

  • Legislative Drafting:Provided technical assistance on bank regulatory, resolutions, and deposit insurance issues; participated in missions to Turkey and the Philippines.
  • Research: Research projects included paper on statutory protections for banking supervisors (see Recent Publications, below), and analysis of banking, central bank and deposit insurance laws for the Global Banking Law Database, www.gbld.org.

1994 – 2000, LAW OFFICE OF ROSS S. DELSTON, WASHINGTON, DC

  • Represented corporate clients, including a Fortune 50 industrial corporation, a major West Coast commercial bank, an S&L holding company, a high-tech company, and two national law firms. Reviewed US government agency compliance program.
  • Client work involved bank regulatory and AML/CFT and OFAC compliance matters relating to electronic banking, new banking activities, branching and licensing issues, trade finance, and FSLIC Resolution Fund transaction.

1991 – 1994, OF COUNSEL, JONES DAY, WASHINGTON, DC

  • Specialized in bank mergers and acquisitions and regulatory matters. Represented a money-center bank in successful bid on an insolvent bank controlled by the FDIC, and a major consumer finance company in chartering an industrial loan company.
  • Testified on open bank assistance before Resolution Trust Corporation Oversight Board; summaries of testimony appeared in the American Banker Newsletter.

1986 – 1991, LEGAL DEPARTMENT, FEDERAL DEPOSIT INSURANCE CORPORATION
Counsel and Assistant General Counsel - Assisted Acquisitions

  • Responsible for the legal work on resolutions of major insolvent banks during US banking crisis, including First City, First Republic, MCorp, Texas American, and Bank of New England, five of the ten largest and most costly bank failures.
  • Created, organized and headed 20-attorney Assisted Acquisitions unit, advised FDIC Chairman and Board of Directors, researched and analyzed regulatory issues.

1976 – 1986, COUNSEL, EXPORT-IMPORT BANK OF THE U.S., WASHINGTON, DC

  • Drafted and negotiated numerous loan, guarantee, and insurance transactions involving Argentina, Brazil, Ivory Coast, Korea, Mexico, and Taiwan.
  • Lead attorney on a $1.5 billion emergency trade credit facility for Brazil, at that time the largest commitment ever authorized by the Export-Import Bank.
  • Traveled to Nigeria, Ivory Coast, Senegal, Ecuador and Bolivia to assess projects.

EDUCATION

  • The George Washington University Law School, J.D., 1976, with honors
  • The George Washington University, B.A., 1973, with Special Honors

MEMBERSHIPS

  • District of Columbia Bar Association, since 1976. Served on Membership Benefits
    Committee, 1995 – 2001 (Best Bar Committee Award, 2000).
  • Women in Housing and Finance, 1991 – present.

RECENT PUBLICATIONS

  • "Smooth sailing or uncertain waters?" Money Laundering Bulletin, November 2006 (front page article on the proposed FinCEN AML regulation for hedge funds).
  • "Emergency Liquidity Financing by Central Banks: Systemic Protection or Bank Bailout?" (with Prof. Andrew Campbell, University of Leeds, UK), Current Developments in Monetary and Financial Law, Vol. 3 (IMF, 2005).
  • "Developing an AML/CFT Strategy and Structure," Building an Effective Anti-money Laundering Regime in Afghanistan (World Bank, 2004).
  • "Lawyers as the New Guardians of Governance," editorial, Amicus Curiae, Journal of the Society for Advanced Legal Studies, London (July/August 2004).
  • "Five Observations About Failed Banks," Current Developments in Monetary and Financial Law, Vol. 2 (IMF, 2003).
  • "Statutory Protections for Banking Supervisors," World Bank Financial Sector Paper No. 4 (1999), a survey of the laws of twenty countries, available on the Bank's web site. A summary of this paper appeared in Part 3 of the IMF’s Supporting Document to the Code of Good Practices on Transparency in Monetary and Financial Affairs (IMF, 2000).
  • Member, International Editorial Board, Journal of Banking Regulation, 2004 – present.

SELECTED RECENT PRESS CLIPPINGS

  • October 9, 2006, Securities Industry News, "Hedge Fund AML Mandates May Soon Be On The Way" (front page article on proposed FinCEN regulations for hedge funds).
  • September 15, 2006, Moneylaundering.com, "New data measures global corruption, governance"(on World Bank study).
  • August 11, 2006, Lipper HedgeWorld News, "US May Expand Treasury Regulation" (on Senate subcommittee report on abuse of corporate vehicles in offshore financial centers).
  • August 7, 2006, Institutional Investor’s Hedge Fund Daily, "IRS: A Fate Worse Than The SEC?" (on anti-money laundering examinations of unregistered hedge funds).
  • June 2006, Money Laundering Alert, "US institutions increase PEP spotlight on domestic politicians" (on politically exposed persons or PEPs), p.11.
  • May 23, 2006, Moneylaundering.com, "FinCEN deficiencies outlined in inspector general report."
  • November 2005, Money Laundering Alert, "On the Job – Countries need entire AML package to help reach compliance" (full page interview, p. 10).

SELECTED RECENT SPEAKING ENGAGEMENTS

November
2006
Pre-conference Workshop on AML for Investment Advisers and Hedge Funds
Institutional Investor Events and compliance reporter, New York City
[Organized and served as workshop leader, and also spoke and moderated panel on independent audits at main conference]
October
2006
Statutory Protections for Financial Supervisors: How to Promote Financial Stability by Enacting the Right Laws
Seminar on Law and Financial Stability
International Monetary Fund, Washington, DC
October
2006
Conducting Good Independent AML Program Audits to Identify Problems Before the Examiners Do
Web Seminar, Alert Global Media and Money Laundering Alert
September
2006
The Proposed AML Rules for Hedge Funds
16th Annual Anti-Money Laundering Audit and Compliance Forum
New York City
[Organized and chaired panel discussion]
June
2006
The 3rd Annual Mutual Fund Forum
Institutional Investor Events
New York City
[Chaired conference]
March
2006
Hedge Funds Enter the World of Anti-money Laundering Compliance
Bloomberg World Headquarters, New York City
[Organized and chaired event]
June
2005
Kiev Workshop for Effective Enforcement of Criminal Justice Measures in Anti-money Laundering in collaboration with the UN Office on Drugs and Crime and the Prosecutor General’s Office of Ukraine
[Organized, chaired and spoke at workshop]
May
2005
Seventh Biennial Regional Central Banks’ Legal Seminar
Central Bank of Aruba
Oranjestad, Aruba
January
2005
Money Laundering Reporting Officers Committee
Law Society of England and Wales, London

A COMPREHENSIVE LIST OF SPEAKING ENGAGEMENTS AND PRESS CLIPPINGS IS AVAILABLE ON REQUEST