Sven Stumbauer

Senior Advisor
Norton Rose Fulbright LLP

United Kingdom
T:+44 20 7444 3492
New York
United States
T:+1 212 318 3000
United Kingdom
T:+44 20 7444 3492
New York
United States
T:+1 212 318 3000
Sven Stumbauer

Sven Stumbauer



Sven is a globally recognized financial crimes expert and forensic investigations professional with over 20 years of experience around the globe. Prior to joining us, Sven was a Managing Director and Global Anti-Money Laundering and Sanctions practice leader at AlixPartners.

Sven's industry experience includes: domestic and international banks; broker/dealers; insurance companies; trust companies; and hedge funds and payment providers, focusing on corporate governance, regulatory compliance, fraud issues, Anti-Money Laundering (AML), Office of Foreign Assets (OFAC), Foreign Corrupt Practices Act (FCPA), the UK Bribery Act (UKBA) and Foreign Account Tax Compliance Act (FATCA) compliance.

He has assisted major financial institutions throughout the world and has a wealth of experience leading complex, high-profile global projects, providing advisory services to clients in over 50 countries, including the US.

He has led major engagements involving AML and sanction compliance, fraud, corruption and regulatory investigations, transactional due diligence and compliance training, to both financial institutions and regulators throughout the world.

Sven has also provided guidance to leading financial institutions and their boards of directors on corporate governance, compliance with the Bank Secrecy Act, the USA Patriot Act, OFAC rules and regulations, FATCA, and the FCPA/UKBA.

He has extensive experience of assisting clients in providing advisory services around government matters involving Deferred Prosecution Agreements, independent monitorships/consultants, cease and desist orders and formal regulatory actions. He has developed and led numerous presentations and/or provided reports to various government agencies such as US: Department of Justice, Office of Foreign Assets Control, Financial Crimes Enforcement Network, Securities and Exchange Commission, Financial Industry Regulatory Authority, Federal Reserve Bank, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, New York State Department of Financial Services, and numerous regulatory bodies across Europe, Latin America and Asia.

Sven frequently publishes and is quoted in well‐known publications such as: The Financial Times, The Wall Street Journal, Bloomberg, International Financial Law Review, China Business Law Journal, International Banker, Law360, Reuters, Compliance Week, Complinet, ACAMS Today, Securities Industry News, The Deal and more.

Sven regularly speaks at global industry conferences and has provided briefings to US and foreign regulatory bodies and prosecutors on emerging issues pertaining to financial crime. He served on the Board of Directors of the Florida International Bankers Association (FIBA), and co‐chair of the FIBA Broker/Dealer Committee, from 2006 ‐ 2015.

Professional experience

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  • Certified Anti‐Money Laundering Specialist (CAMS)
  • Certified Anti‐ Money Laundering Professional (AMLP)
  • FINRA NASD Series 7 license

Financial Institutions

  • Engaged by the SEC appointed Independent Monitor, performed an in-depth review of the BSA/AML and OFAC compliance program and practices of one of the largest Broker/Dealers in the United States. The review covered all areas of the BSA/AML and OFAC compliance program, which included but were not limited to, governance, Know-Your-Customer (KYC) processes and systems, transaction monitoring and sanctions screening systems, as well as internal investigations and regulatory reporting.
  • Conducted an independent sanctions transactions lookback review for one of the world's top five financial institutions in its defense against regulatory findings and the findings of the independent monitor in place, covering over 20 jurisdictions and various sanctions regimes, demonstrating no sanctions violations on the part of the financial institution.
  • Assisted the US branch of a global bank with conducting a customer and transaction review/lookback of 24 months in response to allegations of money laundering and terrorist financing through their foreign branches and the US branch. After conducting the initially mandated transaction review/lookback and one additional targeted transaction review/lookback as mandated by the banks primary regulator, the regulatory mandate was lifted and the bank gained significant regulatory goodwill.
  • Conducted enhanced AML and OFAC due diligence procedures on behalf of a leading U.S. headquartered commodities broker on certain commodities brokers of higher AML/OFAC risk. Subsequently to the initial enhanced due diligence procedures, conducted onsite reviews to determine the viability of entering into a clearing/sub-clearing arrangement. Onsite work was conducted in the following countries: Argentina, Australia, Brazil, Chile, Ecuador, Germany, Hong Kong, Jamaica, Japan, Korea, Mexico, New Zealand, Panama, Russia, South Africa
  • Led an investigation for one of the largest Swiss headquartered global financial institution into certain account relationships to ensure compliance of the financial institution with the terms of the settlement with the US Department of Justice.
  • Assisted numerous non-US headquartered financial institutions to establish/maintain correspondent relationships with their US banking counterparts by enhancing AML/OFAC compliance structures, processes and systems.
  • Advised Panama's Ministerio de Comercio e Industrias on the development of a regulatory framework to supervise currency exchange houses and other financial institutions not being regulated by the Superintedencia de Bancos de Panama.
  • Assisted a global full service commercial, retail and investment bank under a regulatory consent order for deficiencies in the Bank's internal controls in its overall program BSA/AML compliance enhancements. Developed multiple remediation plans across all significant AML related operating areas. Helped create remediation plan for operations and technology. Centralized fraud and investigative units into a single Financial Intelligence Unit. Assisted in redesigning customer due diligence risk model and processes.  
  • Conducted numerous historical transaction reviews/lookbacks on behalf of financial institutions in the U.S. and globally, to oppose regulatory concerns about non-compliance with AML and/or sanctions/OFAC requirements resulting in either alleviating regulatory concerns entirely and avoiding formal regulatory actions, or significantly reducing potential monetary fines and censures.
  • Conducted numerous customer and transaction reviews/lookbacks, mandated by several regulatory bodies including the Federal Reserve, OCC, FDIC, FINRA and others, each engagement leading to full satisfaction of the regulatory mandate.
  • Assisted a global full service retail and commercial bank in generating a consolidated view of its global customers by: 
  1. determining process to execute an initial consolidation and developing a sustainable solution while considering global privacy implications
  2. creating a global process to consolidate customer information without violating privacy requirements across hundreds of jurisdictions
  3. developing technology algorithms to identify global customers with accounts across jurisdictions
  4. utilizing the initial review to define requirements for global customer monitoring and KYC system without violating ongoing privacy requirements across different jurisdictions
  5. executing a remediation program to expand KYC information for global high risk customers.
  • Assisted a large Latin American financial institution in conducting a gap analysis and review of its AML/OFAC compliance including policies, procedures, processes, and controls; developed and delivered a bank-wide training program providing focused training to Board of Directors, lines of business, areas of high risk, and new hires. In addition:
  1. assisted with restructuring of the AML/OFAC compliance function at the financial institution, including the remedial and implementation work around AML/OFAC policies, procedures and systems.
  2. assisted with the assessment of risks specific to products and services, customer types, geographies, and anticipated activity; assisted with the identification of high-risk customers; provided a customized risk rating tool; and assisted with the gap analysis of the existing customer base as well as new account opening.
  3. developed AML certification for correspondents and affiliate; assisted with implementation and fine tuning of AML/OFAC transaction monitoring systems and related policies, and procedures.
  4. assisted with the implementation of corrective actions and validated the implementation after the controls were in place for a period of time to provide additional re-assurance to the Board of Directors.
  5. the assessment and implementation assistance allowed the Bank to elevate its AML/OFAC Program to meet regulatory expectations and resulted in the creation of new correspondent relationships in the US and Europe.



  • U.S. Fortune 100 company - assisted the chief compliance officer of a multinational conglomerate in performing a review of the company's anti-bribery and corruption (ABC)/anti-money laundering (AML)/Office of Foreign Assets Control (OFAC) program. The project involved testing the degree to which the ABC/AML/OFAC program had been implemented across multiple operating companies by reviewing on-site documentation, conducting interviews with operating company management, and performing targeted reviews of financial records and transactions.
  • Colombian Headquartered Industrial Conglomerate - conducted a comprehensive customer, vendor and third party risk assessment focusing on AML, terrorist financing, OFAC compliance and FCPA/UKBA compliance aspects. Subsequent to the completion of the risk assessment, we assisted the company in developing a robust financial crimes policy covering all financial crimes related risks, and assisted with the implementation through the creation of risk-based operational procedures and related systems.
  • Leading Private Equity Investors - conducted over 50 M&A due diligence engagements globally on behalf of financial and strategic buyers, focusing on potential deal breakers, and assessment of internal control environments and regulatory exposures, including those relating to AML, OFAC, FCPA and other similar ABC laws and regulations. Jurisdictions involved: Albania, Argentina, Bolivia, Brazil, Chile, Colombia, Costa Rica, Czech Republic, Ecuador, El Salvador, Germany, Guatemala, Honduras, Hong Kong, Japan Mexico, Nicaragua, Panama, Paraguay, Peru, Poland, Russia, Singapore, South Korea, United Kingdom, Uruguay and Venezuela.
  • The Continued Struggle with  Anti-Money Laundering Compliance: Ongoing Challenges and Opportunities for Financial Institutions, International Banker, March 2020
  • Paradise Lost or Money Laundering Paradise, Ethical Boardroom July, 2019
  • The End of European Money-Laundering Scandals, or Just the Beginning?, International Banker, June 2019
  • Swedbank's handling of money laundering scandal a lesson in fallibility, Financial Times, March 2019
  • 은행권, 올해 FATF 평가 앞두고 AML∙FDS 고도화 착수 – eEtNews, January 2019
  • Trends and challenges in anti‐money laundering and sanctions compliance for Korean Financial Institutions, Legal Times, December 2018
  • Aussichtsloser Kampf gegen illegale Geschäfte ‐ WirtschaftsWoche, December 2018
  • Der fast aussichtslose Wettlauf gegen Briefkastenfirmen, WirtschaftsWoche, December 2018
  • Bank Boards Continue to Fall Short Against Money Laundering, Survey Finds, The Wallstreet Journal, November 2018
  • 何志平跨國行賄紐約候審罪成最高可囚20年 – Epoch Times, November 2018
  • AlixPartners' 2018 Global Anti‐Money Laundering and Sanctions Compliance Survey, November 2018
  • 법무법인 광장, '글로벌 자금세탁 규제' 세미나 개최 – Segye News, November 2018
  • Over $1 trillion flowed through Estonia between 2008 and 2015, dwarfing Danske Bank money laundering scandal, Financial Post, October 2018
  • 6.500 milliarder strømmede gennem estiske banker på syv år , Finans, October, 2018
  • Kako je majhna Estonija postala velika pralnica denarja ‐ ‐ October 2018
  • Top Consulting Firms and Forensic Investigators, Global Investigations Review (GIR), October 2018
  • Eesti pankadest käis läbi triljon dollarit mitteresidentide raha, Postimees, October 2018
  • Naming of Jailed Banker's Wife Sends Warning as U.K. Fights Money Laundering, The Wallstreet Journal, October 2018
  • US‐Justiz ermittelt gegen Danske Bank, Deutsche Wirtschafts Nachrichten, October 2018
  • Financial Crime Wave ‐ Estonia Laundering Update ‐ Association of Certified Financial Crime Specialists, October 2018
  • How Estonia's money‐laundering scandal unfolded, The Week, October 2018
  • Bankexpert: Danske i Estland bara toppen på isberget, Realtid, October 2018
  • Estonia Banks Did $500 Billion in Cross‐Border Flows ‐ Bloomberg, October 2018
  • South Korean financial institutions are not sufficiently prepared for U.S. Anti‐Money Laundering and Sanctions Scrutiny, The Bell, September 2019
  • Hong Kong Business Tycoon Accused of Money Laundering, Channel News Asia, September 2018
  • Compliance in Chinese banks: Playing catch‐up – Ethical Boardroom July, 2018
  • Investors Cozy Up to Compliance Opportunities ‐ The Wall Street Journal, July 2018
  • Identifying Ultimate Beneficial Ownership Regulators' Key AML focus, Asian Private Banker, July 2018
  • 알릭스파트너스 "금융기관, 암호화폐 통한 자금세탁 대비해야 ‐ Edaily Korea, July 2018
  • 한국 금융기관 자금세탁방지 준비 경영진 적극 개입 필요 ‐ FNNews Korea, July 2018
  • In the 'Wild West' of Virtual Currencies, Anti‐Money Laundering and Sanctions Enforcement is Anything but Virtual, Corporate Compliance Insights, June 2018
  • Crypto Exchanges Must Up Their AML Game, Markets Media, May 2018
  • PB directors can turn dirty business squeaky clean, CityWire, May 2018
  • Chinese banks need to firm up AML compliance, International Financial Law Review, May 2018
  • The Top Anti‐Money Laundering and Sanctions‐Compliance Challenges for Financial Institutions in 2018 and Beyond, International Banker, March 2018
  • Hong Kong banks' efforts against money laundering to face scrutiny as global regulator's visit looms, South China Morning Post, February 2018
  • Chinese banks warned on anti‐money laundering compliance, China Business Law Journal, February 2018
  • Getting real on AML and sanctions compliance challenges in APAC, Fintech Innovation, January 2018
  • AML and sanctions compliance still not high priority for boards, FCPA Blog, January 2018
  • Bekaempfung der Geldwaesche, Compliance Magazin Deutschland, January 2018
  • Blocked by CFIUS, Ant Financial Abandons Plan to Acquire MoneyGram and Shifts to Strategic Cooperation, Caixin Global, January 2018
  • Banken erwarten noch hoehere Compliance‐Kosten, BoersenZeitung, January 2018
  • Finanzdienstleister sind auf die Risiken durch Geldwäsche schlecht vorbereitet, Banken & Partner, January 2018
  • Getting Real on AML and sanctions compliance challenges in APAC, Fintech Innovation, January 2018
  • Needless 'de‐risking' might increase AML risk, Asian Private Banker, December 2017
  •  20% of Bank Boards Don't Receive AML Training, The Wall Street Journal, December 2017
  • AlixPartners'  2017 Global Anti‐Money Laundering and Sanctions Compliance Survey,December 2017
  • US Pursues Alleged Chinese‐Africa Bribery Through Finance Ties, The Wall Street Journal, November 2017
  • US Puts Banks on Notice With 'Recipe Book' on North Korea, The Wall Street Journal, November 2017
  • It's 'winner takes all' for banks that can get compliance right, South China Morning Post, October 2017
  • The Commonwealth Bank could face enforcement action from US regulators over its alleged failure to comply with anti‐money laundering laws, Lawyers Weekly, September 2017
  • US lawyers warn CBA could face foreign regulatory action , Corporate Counsel, September 2017
  • New Venezuela sanctions 'big deal' for banks; five steps to comply, Reuters/Complinet, August 2017
  • Riesgos e implicaciones de hacer negocios en Venezuela, The Miami Herald / El Nuevo Herald, August 2017
  • Mexico Bulks Up Anti‐Corruption Law, The Wall Street Journal, July 2017
  • Education Can Help Manage De‐Risking Fallout, The Wall Street Journal, July 2017
  • The (Not so Obvious) Top 3 Cost Drivers of Anti‐Money Laundering Compliance, International Banker, June 2017
  • US report and Trump administration's tone suggest tougher AML enforcement in Asia, Ownership Transparency, June 2017
  • Se ha incrementado el refinamiento de los lavadores, El Pais, May 2017
  • Bank De‐Risking Provides an Opening for Chinese Rivals, The Wall Street Journal, May 2017
  • European Banks Unite to Tackle Human Trafficking, The Wall Street Journal, March 2017
  • Five Steps for Anti‐Money Laundering Compliance in 2017, International Banker, February 2017
  • Accountability for money laundering risk in the first line of defense, 1LoD Summit, London, November 2019
  • Corporate governance and enterprise wide risk management challenges for financial institutions in Mexico, FIBA LatAm Financial Crime Conference, Mexico City, June 2019
  • Europe – Paradise Lost or a Money Laundering Paradise? What policymakers, regulators and banks got wrong in light of recent money laundering scandals and the path forward, Harvard University – Kennedy School, Boston, MA, April 2019
  • Global trends and challenges in anti-money laundering, sanctions and anti-bribery and corruption compliance and the role of board of directors, EGADE Business School del Tecnológico de Monterrey, Mexico City, April 2019
  • AML and OFAC challenges for foreign financial institutions in the US, Institute of International Bankers Annual US Regulatory/Compliance Orientation Program, New York, December 2018
  • AML이 뭐길래...잘못하면 세컨더리 보이콧,  Naver, South Korea, November 2018
  • Keynote address: Trends and challenges in anti‐money laundering and sanctions compliance for Korean Financial Institutions, South Korea, November 2018
  • Keynote address: US Anti‐Money Laundering and Sanctions Enforcement Actions and their Implications for Japanese Financial Institutions, Tokyo, November 2018
  • Keynote address: US Anti‐Money Laundering and Sanctions Enforcement Actions and their Implications for Hong Kong's Financial Institutions, Hong Kong, November 2018
  • Challenges of Legacy Monitoring Systems,  Jamaica Bankers' Association 7th Annual Anti‐ Money Laundering/Counter‐Financing of Terrorism Conference, Jamaica, October 2018
  • Keynote address: The Top Anti‐Money Laundering and Sanctions Compliance Challenges for Financial Institutions for 2018 and Beyond, Innoxell Asia Pacific Summit 2018, Hong Kong, April 2018
  • Leveraging Technology in Anti‐Money Laundering and Sanctions Compliance, Innoxell Asia Pacific Summit 2018, Hong Kong, April 2018
  • The complex challenges associated with correspondent banking relationships, 2nd Trade Finance and Correspondent Banking Compliance Conference, Singapore, October 2017
  • How to setup and maintain a mutually satisfactory correspondent banking relationship, 19 Seminario Internacional de Prevencion de Lavado de dinero y Combate al Financiamiento del Terrorismo, Mexico, October 2017
  • El nuevo enfoque del Norte en Transparenca del Beneficiario Final, Antilavado y contral el Financiamiento del Terrorismo, 5to Congreso de Prevencio de Lavado de Activos de las Americas, Uruguay, May 2017
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