Treasury, a top-15 bank, Meta, Big Four

I've spent seventeen years on four sides of the same problem: writing sanctions designations and intelligence products for U.S. Treasury, running second-line AML advisory and sanctions governance at a top-15 U.S. bank, leading global sanctions operations for a technology payments platform, and advising fintechs and banks as a Big Four consultant.

That range is the reason I started Plath Advisory. Early-stage companies have to move fast, and a cut-and-pasted BSA program running out-of-the-box settings is the surest way to stop progress. I build bespoke, right-sized BSA/AML and sanctions programs, with systems and thresholds calibrated to your risk appetite and the footprint of each product and service, so controls scale with the business instead of blocking it.

I've written the evidentiary package components behind a designation, owned the screening model and approved its tuning, built the controls for a product team and then explained them to a regulator, and led global teams through the remediation that follows when the business has outpaced a nascent program. That's a different conversation than the one you'll have with a firm that has only ever assessed someone else's work.

The path here

I started as a Surface Warfare Officer aboard a guided-missile destroyer and an aircraft carrier, then moved to the Defense Intelligence Agency's Counter-Terrorism Fusion Center. That led to threat finance work, including a six-month deployment to the Iraq Threat Finance Cell, briefing generals and admirals, Treasury officials, and tactical teams on how terrorist networks actually raised and moved money.

At BAE Systems, I spent five years supporting the Treasury Department, managing a sanctions support contract to OFAC and authoring designation evidentiary packages within Treasury's Office of Intelligence and Analysis alongside the Office of General Counsel. That's where I learned what sits behind a name on the SDN list, and why screening is far more than a data-matching problem.

I moved to the private side at Citizens Bank as Head of AML Advisory and Sanctions Governance, reporting to the BSA Officer. Over five years I owned the enterprise risk assessment program, led the customer due diligence program through FinCEN's CDD Final Rule, served as model owner for the bank's screening platforms, and executed core BSA Officer responsibilities including SAR and CTR governance, 314(a) and 314(b) responses, OFAC reporting, and board-level program effectiveness reporting. I led examinations with the OCC and FDIC and wrote the AML and sanctions requirements for new card products, fintech partnerships, and the bank's real-time payments initiative. I also championed the bank's addition to the SWIFT KYC Registry, which cut correspondent-bank response time from two hours to two minutes. That's where I learned what a program looks like when it has to satisfy an examiner, a board, and business line stakeholders in the bank at the same time.

Then I went to Meta as Head of Global Sanctions Operations for Meta Payments, a turbo-charged environment where compliance had to keep pace with product. I built the sanctions framework behind global payments launches reaching millions of consumers, advised the Novi/Libra stablecoin program on sanctions framework design, and led a regulatory examination with the Central Bank of Ireland. I also served as compliance liaison to the sponsor bank through its 50% Rule screening gap, running vendor selection, implementation, and remediation while keeping the bank engaged throughout. That's where I learned to build controls that don't become the reason a launch slips.

Between Meta and PwC, I spent a year founding and running my own company, an e-commerce business I built past six figures in revenue in its first year. That's where I learned what a P&L feels like when it's truly yours.

Most recently, I spent four years as a Senior Manager in PwC's Financial Crimes Advisory practice, advising fintech, payments, crypto-adjacent, and banking clients on program design and remediation. I directed a global sanctions investigations program for a Fortune 500 fintech, designed machine-learning-assisted screening and investigation automation projected to cut alert-handling time in half, and built diligence frameworks for emerging regulatory regimes. Seeing dozens of programs in four years taught me something no single institution can: which control gaps are idiosyncratic and which ones are common. It's a benchmark I bring to every engagement, paired with the experience of having built the controls myself rather than just assessed them.

I hold the Certified Anti-Money Laundering Specialist (CAMS) designation from ACAMS, and I'm a graduate of the U.S. Naval Academy.

How I work

Compliance is how regulated businesses grow. That's harder than it used to be: payment rails run around the clock, stablecoins settle in seconds, and most of it happens with no human in the loop. Programs fail in both directions. Too permissive and you fail the exam. Too rigid and you fail the business. Getting that calibration right, for your products and your risk appetite, is the whole job.

My job is to find the compliant path to yes. Sometimes that means telling you a product can’t launch the way you've designed it. But I'll come back with the control, the threshold, or the structure that gets it to launch compliantly, and that holds up when an examiner asks why, two years later.

If that's the kind of conversation you want to have, let's talk.

A man with a shaved head and beard wearing a dark blue suit jacket and a light blue dress shirt, standing outdoors with blurred trees in the background.
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