Expertise
Compliance Program Assessment & Exam Preparation
Patomak Global Partners assesses compliance programs at banks, broker-dealers, swap dealers, security-based swap dealers, futures commission merchants, consumer lenders, mortgage servicers, digital asset trading platforms, fintechs, and other financial firms to identify control weaknesses or gaps. The team provides recommendations to remediate identified issues and conducts follow-ups to ensure successful remediation.
The team works with executives to prepare clients for examinations by U.S. banking regulators, the Consumer Financial Protection Bureau, the Commodity Futures Trading Commission, the Financial Crimes Enforcement Network, the Financial Industry Regulatory Association, the National Futures Association, the Securities and Exchange Commission, and other authorities.
Regulatory Licensing
We assist firms in designing and implementing compliance frameworks for regulatory licensing to help ensure the approval process, and consummation goes smoothly. To support these efforts, the team develops policies, procedures, and internal controls for trading, risk management, margin, capital, compliance, cyber security, anti-money laundering, know-your-customer requirements, community reinvestment and consumer compliance, and other functions considered during the licensing process.
BSA/AML & Sanctions Compliance
The team strategically supports the design, implementation, and enhancement of BSA/AML and sanctions policies, procedures, and processes, including assessing vendor solutions.
Governance & Supervision
Patomak reviews governance frameworks and advises clients regarding shareholder relations, management duties and responsibilities, risk control, assessment programs, supporting independent review functions (e.g., audit, credit, model, etc.), and committee structures and charters.
Risk Management & Regulatory Reporting
We assess the design and implementation of risk management, trade surveillance, and reporting (SDR, CAT, TRACE, LTR) systems to ensure they meet regulatory requirements.
Team members also review capital, credit, liquidity frameworks, and regulatory capital modeling approaches to ensure clients exceed regulatory expectations.
Regulatory Technology & Operations Implementation
Patomak helps clients execute complex regulatory technology and operational initiatives by translating regulatory requirements and assessments into scalable operating models, governance frameworks, controls, data capabilities, and technology solutions. Working directly alongside client teams, we advise clients on the design, implementation, testing, and operationalization front-to-back capabilities across the entire trade lifecycle within the securities and derivatives markets.
To support these efforts, the team provides advice across the full implementation lifecycle, from strategy and program mobilization through requirements definition, solution design, systems integration, testing, regulatory readiness, and post-implementation optimization. We also advise established firms and new firm entrants, including prediction markets and digital asset firms, on enterprise-wide initiatives such as enterprise data management (governance frameworks, data lineage, and reporting quality), systems architecture (vendor evaluation, systems integration, and technical testing), regulatory change execution, and AI strategy and integration.
Representative Engagements
Examples of the Patomak Global Partners’ risk management and compliance engagement include:
Compliance Assessment & Exam Preparation
- Supported a bank’s efforts to develop and document risk management processes responsive to Federal Reserve Board findings and requirements, focusing on banking services provided through its clearing account.
- Conducted a comprehensive review of a global financial institution’s trade surveillance program across jurisdictions and products. Review included assessing and providing expert advice related to the trade venue inventory, supervision, and parameter setting.
- Conducted end-to-end trade reporting reviews for multiple swap dealers focusing on large trader reporting, real-time public reporting, and data recordkeeping to assess compliance with CFTC parts 20, 43, and 45.
- Assisted with compliance reviews, annual compliance and risk assessments, and Form ADV filings for SEC-registered investment advisers of foreign investment managers.
- Reviewed and assessed financial firms’ off-channel communication compliance program, taking into account undertakings in recent SEC enforcement actions.
- Assessed compliance with CFTC regulations covering policies, procedures, and controls for several major swap dealers, focusing on supervision, business conduct, clearing and execution, and large trader reporting.
- Conducted independent reviews for a large financial institution with multiple broker-dealers to support CEO certification regarding SEC Rule 15c3-5 (Market Access) compliance, including financial, regulatory, and other risk management controls and supervisory procedures.
Regulatory Licensing
- Served as an implementation partner for many firms to successfully secure CFTC and NFA registration as a swap dealer and assisted with end-to-end implementation of a compliance and risk management program spanning trade surveillance, margin, capital reporting, and client onboarding.
- Supported cryptocurrency firms’ successful applications for New York BitLicense and state-level trust company charters, including advising on policies and procedures and conducting required risk assessments.
- Advised bank executives on the requirements, timeline, and regulatory risks related to the application process to become a member bank of the Federal Reserve System.
BSA/AML & Sanctions Compliance
- Developed processes at banks to stand up a CIP and KYC programs to comply with FinCEN requirements.
- Developed policies and procedures, trained staff, conducted internal reviews, and managed annual employee certification on FCPA requirements.
- Assessed the adequacy of BSA/AML and sanctions programs for global cryptocurrency trading platforms, including reviews of the adequacy of vendor solutions as well as policies and procedures.
Governance & Supervision
- Trained employees at a major bank on new risk management processes and validated sustained implementation of new processes.
- Audited board and management governance of a bank’s relationships with its third-party customers and vendors, including BSA/AML, UDAAP, and fair lending risks.
- Performed a detailed review, analysis, and assessment of a hedge fund’s policies, procedures, systems, and controls to prevent the misuse of material non-public information by its employees and insider trading.
- Conducted an independent and holistic review, analysis, and assessment of policies and procedures related to board governance and clearing activities at a major clearinghouse.
Risk Management & Regulatory Reporting
- Reviewed all aspects of enterprise risk management for a global financial institution to include culture and tone, governance and structure, reporting and management, control and mitigation, monitoring, risk measurement, and independent review functions.
- Analyzed risks and controls related to business processes at a major consumer lender to ensure compliance with CFPB regulations and identify deficiencies.
- Served as an independent compliance consultant pursuant to a FINRA enforcement action regarding a broker-dealer’s compliance with Blue Sheets and TRACE reporting.
- Conducted for an intermediate holding company a gap analysis of capital and liquidity risk management approaches, supporting executive-level responses to regulatory scrutiny regarding these areas.
Regulatory Technology & Operations Implementation
- Served as the primary implementation consultant for firms pursuing SEC, CFTC, and NFA registrations by advising on the design of end-to-end regulatory, compliance, operational, and data infrastructure.
- Led front-to-back operational and tech build-outs for swap dealers, security-based swap dealers, and broker-dealers, managing vendor selection, systems integration, and regulatory readiness.
- Designed enterprise data governance frameworks supporting regulatory reporting and recordkeeping, including data rationalization, data mapping, and data controls to monitor, manage, and improve data quality, while supporting data issue identification, remediation, and ongoing governance.
- Recommended reporting implementation initiatives across SEC and CFTC regimes, including business process redesign, reporting controls implementation, and establishment of sustainable operating models.
- Built custom change management capabilities to facilitate dynamic adaptation of operating models, data structures, and technologies to shifting expectations.
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