I help leaders make better decisions by connecting strategy to the systems, models, data, and governance underneath it.
For more than twenty-five years inside major U.S. financial institutions, I built risk capabilities from the ground up — economic capital and stress‑testing frameworks, interest‑rate risk systems, and an AML data science function using machine learning. I also built the governance around them and learned how to make the work stand up to regulatory, audit, and independent review.
Today I advise primarily on the AI technology and related governance needed to combat financial crime. However, given that background I am also available to assist with broader enterprise risk questions. Since I remain a builder at heart, I continue to develop new tools, frameworks, and ventures of my own.
Provided strategic direction on AML technology to an international FIU to help them chart a path through their current plans to the next generation of detection and investigation capabilities.
International FIUPNC · 2017–2025
Machine learning worth $5M in efficiency
The program relied on rules that had outlived the typologies behind them. We integrated supervised classification and clustering into AML models, delivering more than $5 million in operational efficiency — fewer false positives and more true positives, not a trade of one for the other.
Regulators care about behavior detection coverage before they care about elegance. We moved the program off inefficient rules to full adoption of machine learning algorithms, and closed the open coverage requirements in the same work.
coverage maintained through the transitionPNC · 2017–2025
Model governance that cleared regulatory findings
Machine learning in a regulated detection program is only allowed if it can be examined. We built the formal modeling governance structure that made the AML models defensible — and cleared the open regulatory findings against the program.
MRAs clearedPNC · 2017–2025
Cross-bank detection without sharing data
Detection has a coverage gap no single bank can close alone. Partnering with a start-up, we pioneered federated learning architectures for cross-institutional behavior detection — sharing intelligence while preserving privacy and data sovereignty.
Named inventor on two pending U.S. patent applications in AML detection technology, assigned to PNC — US 2025/0156940 A1, on efficient detection of money laundering, and US 2025/0348880 A1, on monitoring customer transactions for potential financial crimes.
Defined where fraud and AML integration created value
Fraud and money laundering increasingly share common data, behavioral signals, and investigative tools. I helped define where integration between fraud and AML made practical sense — particularly across data management, analytical tools, and shared features — and helped shape the AML team’s contribution to the broader FRAAML integration program.
FRAAMLPNC · 2017–2025
Graph analytics that row-by-row analysis misses
I introduced graph analytics to map the relationships between products, typologies, and models — and to surface unusual peer-to-peer transactions that row-by-row analysis cannot see.
products × typologies × modelsPNC · 2008–2017
Architected the firm’s first stress test
After 2008, supervisors wanted stress testing no one had built yet. I architected and operationalized the firm's first Supervisory Capital Assessment Program — a precursor to CCAR — by developing a multi-risk stress testing framework that exceeded what the regulators asked for.
precursor to CCAR · exceeded expectationsPNC · 2008–2017
Reconciled three capital measures into one view
Risk-weighted assets, economic capital, and stress-test capital each said something different about the same balance sheet. We reconciled RWA, economic capital under both Value-at-Risk and Expected Shortfall, and CCAR stress measures — turning three incompatible answers into differentiated insight that supported capital adequacy assessment and regulatory reporting.
RWA · VaR / ES · CCARPNC · 2008–2017
Measured how risks actually move together
Aggregating risk means knowing how risks move together. We improved portfolio concentration analysis and measured inter-risk correlation, so aggregation and scenario analysis rested on measured relationships.
Pricing that ignores capital cost misprices risk. We advanced correlation models across retail, commercial, and CRE portfolios, bringing loan pricing into alignment with capital costs, risk appetite, and origination strategy.
retail · commercial · CREPNC · 2008–2017
Founded the committee that aligned capital and pricing
Capital estimation was opaque to the people making pricing decisions. I founded and chaired the Economic Capital Committee, aligning risk modeling, capital planning, and RAROC so that strategic pricing decisions rested on numbers everyone had agreed to.
RAROC · strategic pricingNational City · 2003–2008
Built National City’s first enterprise capital framework
Regulators wanted an enterprise view of capital that the bank did not have. I led the design and implementation of an enterprise-wide economic capital modeling and regulatory capital reporting framework at National City — the first the firm had. After the merger it became the foundation PNC integrated onto.
enterprise-wide · built from nothingNational City · 2001–2003
Liquidity forecasting across multiple horizons
The bank's liquidity process could not see far enough ahead. I designed and implemented a multi-horizon liquidity forecasting capability inside the QRM simulation model, so liquidity could be managed on the same platform as rate risk.
QRM · multi-horizonNational City · 2001–2003
Added the mortgage driver ALCO was missing
Income volatility analysis was missing its biggest driver. I initiated development of a mortgage loan production forecast model built on macroeconomic drivers, then folded it into the QRM earnings-at-risk simulation framework to provide ALCO with a holistic view of enterprise interest rate risk exposures.
macroeconomic drivers · EaRNational City · 2001–2003
Embedded optionality captured in economic value-at-risk
I established an economic value-at-risk framework to assess long-term market value sensitivity, fully capturing embedded optionality across products ranging from MBS and whole‑loan mortgages to non‑maturity deposits — the features that often drive a bank’s underlying interest‑rate risk.
EVaR · Embedded optionsNational City · 2001–2003
Founded ALCO’s mortgage earnings-at-risk subcommittee
The bank's reliance on mortgage banking revenue was not visible enough to manage. I founded and chaired the Mortgage Banking Earnings-at-Risk Committee, a subcommittee of ALCO, integrating repricing risk, credit spreads, and loan demand elasticity to optimize risk-adjusted profitability.
ALCO subcommitteeIACPM · 2018–present
Teaching the credit portfolio toolkit internationally
I delivered the Active Credit Portfolio Management toolkit at three IACPM Annual Meetings — Stamford, Miami, and Washington — then recorded it for the Online Educational Seminar in 2022 and refreshed it in 2025. It has run every year since. I previously served on a working group on evolving capital approaches.
curriculum · working group · Senior AdvisorPNC · 2017–2025
Built PNC’s AML data science function from nothing
I established the AML Data Science Solutions team at PNC and directed the design and oversight of both traditional analytics and machine-learning detection across transaction monitoring, sanctions screening, and customer risk rating — a function that did not exist before it was built.
founded the functionPNC · 2017–2025
Restarted a 40-bank consortium and gave it governance
A consortium of more than forty North American banks had not met since 2019 — its leader retired, then COVID arrived, and it stopped. In 2023 I brought it back, then led the member discussions that produced what it never had: an agreed organizational structure and governance model for running it year over year. I served the first one-year term as President and handed it on.
40+ institutions · one-year termPNC · 2008–2017
Merged two capital frameworks with a 35-person team
Post-merger, two capital frameworks had to become one. I led the integration at PNC, managing a 35-member cross-functional team spanning quantitative analytics, operations, and model governance, along with the budget and vendor relationships behind it.
35-member team · budget & vendor ownershipPNC · 2008–2017
Translating models for ALCO, the board, and regulators
Modeling only matters if the answer lands. Across ALCO, executive committees, the board, and regulators, my role was translating what the models said into decisions people could actually take.
ALCO · board · regulatorsPNC · 2017–2025
Change control that made models defensible
I implemented a change control framework across model development so that what changed, when, and why was transparent — the difference between a model you can defend and one you can only explain.
transparency in developmentPNC · 2008–2017
Documented for examination before examiners asked
I represented the modeling teams before regulators across capital and AML, which shaped how we documented and evidenced the work long before any examination began.
OCC · FinCEN
25+ years on the inside.
I have spent much of my career building risk capabilities before they became standard practice. My career has largely been about taking on new problems as the risks facing banks changed.
I came to risk from the business side. Before I built my first risk model I worked in commercial credit, commercial real estate and small business lending, branch banking, funds transfer pricing, and mergers and acquisitions. That is still how I judge a risk framework: whether it changes a decision someone is about to make.
At National City, I began by working on the measurement of interest‑rate risk. I led the implementation of the firm’s QRM interest‑rate risk management platform, incorporating economic value of equity into the IRRBB framework, calibrating mortgage prepayment and non‑maturity deposit behavior, and implementing earnings‑at‑risk simulation. As the work matured, I founded and chaired the Mortgage Banking Earnings‑at‑Risk Committee, creating a direct link between what the models were telling us and the people making balance‑sheet and business decisions.
From there, my focus broadened from individual risk types to the enterprise as a whole. I built National City’s first enterprise‑wide economic capital framework, establishing a common basis for allocating capital across credit, market, operational, interest‑rate, and business risk. After the financial crisis, that work evolved again as supervisory expectations changed. I architected and operationalized the firm’s first Supervisory Capital Assessment Program, the precursor to CCAR.
When PNC acquired National City, I continued that work on a much larger scale, expanding credit‑risk economic capital capabilities for the combined portfolio and strengthening governance of the enterprise framework. I founded and chaired the Economic Capital Committee to bring consistency and senior oversight to how the framework was used across the organization.
Later in my career, I moved into financial crime, where I saw another opportunity to build a capability that did not yet exist. I was an early proponent of machine learning in this space and established AML Data Science Solutions at PNC, a cross‑functional group supporting transaction monitoring, sanctions screening, customer risk rating, and operations simulation. We developed the standards and model governance needed to use machine learning in a regulated environment. The work helped resolve outstanding regulatory findings and generated more than $5 million in operational efficiencies.
That progression — from interest‑rate risk, to enterprise capital, to stress testing, and ultimately to machine learning and financial crime — is the consistent thread in my career: taking emerging or complex problems, building the analytical and governance structures needed to address them, and connecting the results to real business decisions.
Career
2026–presentPrincipal ConsultantCXO Partners
2025–presentFounder & PrincipalSemper Clarus Risk Advisors
2025VP, AML Data & Model Management — Canada, Europe & Asia PacificTD Bank Group
2017–2025SVP, Head of AML Data Science SolutionsPNC Financial Services Group
2008–2017SVP, Head of Economic Capital GroupPNC Financial Services Group
2003–2008SVP & Manager, Economic Capital GroupNational City Corporation
2000–2003VP & Manager, Interest Rate Risk AnalysisNational City Corporation
1998–2000Senior Asset Liability AnalystNational City Corporation
Education
MS, Management Science & Operations ResearchCase Western Reserve University
Senior AdvisorInternational Association of Credit Portfolio Managers
Board member, formerDance Cleveland · Center for Arts Inspired Learning
TreasurerChurch finance — automated budgeting, formal procedures, and a pension review that saved $50,000
Advisory
Risk work, led personally.
I work with banks and financial institutions on AML and financial crime detection, capital and balance‑sheet risk, and AI and agentic risk governance — from fractional and interim risk leadership to board and executive advisory. Every engagement is written to be defended in front of a board, an auditor, or an examiner.
I have deep experience presenting to large and small audiences on a broad range of topics, and am open to new speaking opportunities.
40 engagements · 2007–2026
2026GFMIBuilding a Responsible AI Playbook for Risk TeamsDay 2 closing workshop2026Georgetown UniversityThe Future of Financial Integrity: Technology & Risk IdentificationPanelist with Francisco Okecki2025Fidelity / SaifrMyth Busters — six thoughts holding back innovation in AML/KYCWebinar with Jon Elvin2025American University, School of International ServiceIntroduction to Combating Financial Crimes, Terrorist Financing, and Human TraffickingPolitics, Governance & Economics group2025CIO CISO Think TankDriving Innovation: Five Critical Success FactorsGuest speaker2022–2026IACPM Online Educational SeminarActive Credit Portfolio Management: Techniques and ToolkitRecorded 2022, refreshed 2025 · run annually since2024Ai4 Las VegasHow AI Is Helping To Take The Risk Out Of Risk ManagementPanel with Agus Sudjianto (Wells Fargo) and Kathleen Li (Extend)2023Ai4 Las VegasThe AI/ML Assist — Anti-Money Laundering and Countering the Financing of Terrorism2022Case Western Reserve UniversityAnalytics in Action — Role of Analytics in AML2022Florida International Bankers AssociationInnovative Technologies in AML2022McKinseyMachine Learning and AML: A Path for AdoptionNorth American AML Analytics Roundtable2022New York City Bar AssociationOpportunities and Challenges in AML and CFTPanel2021Banking Transformation ForumThe Evolving Nature of Financial and Cyber Crime Behavior Detection2021Federated Learning and Distributed Machine Learning ConferenceAML Challenges and Potential Benefits of Federated Learning2021Association of Certified Financial Crime SpecialistsThe MRM/AML Peace Accords — Successfully Applying Model Risk Management to AMLPanel2020IACPM Annual Meeting · Washington DCActive Credit Portfolio Management: Techniques and ToolkitIn-person workshop2020ABA Compliance and Risk ConferenceRole of AI in Compliance and AML2020Florida International Bankers AssociationRole of AI in AML2020Promontory AML Analytics Round TableMachine Learning & Analytics in BSA/AMLPanel2019IACPM Annual Meeting · Miami, FLActive Credit Portfolio Management: Techniques and ToolkitIn-person workshop2019AML SummitApplications of Machine Learning to Enhance AML Effectiveness and Efficiency2019AML SummitPrinciples and Procedures Working Group — common AML modeling approaches across member banksPresenter2018IACPM Annual Meeting · Stamford, CTActive Credit Portfolio Management: Techniques and ToolkitIn-person workshop2017Capital Allocation & Stress Testing Conference11th AnnualConference chair & presenter2016GAARP ConferenceRisk Practitioners and their Role in Changing the Banking Industry2015IACPM Annual Fall ConferenceAddressing Risk/Return — Current Environment2014GFMI Capital Adequacy, Strategy and Stress Testing ConferenceEconomic Capital = Value+2014Moody’s Credit Practitioner’s ConferenceEconomic Capital in the Age of CCAR2014Moody’s Credit Practitioner’s ConferenceBalancing Economic and Regulatory CapitalPanel2012RiskMindsThe Divergence Between EC and RC and Its Implications for Capital Management2011RiskMindsManaging Capital: New Regulations, New Constraints and New Incentives2011IACPM Annual Fall ConferenceResults from Economic Capital Benchmarking Survey2011Case Western Reserve UniversityStatistics, Quantitative Skills, and Banking2010RiskMindsIssues, Tools, and Processes that Banks will Need to Address Their ICAAPs2010IACPM Annual Fall ConferenceEconomic Capital Survey Results2009Incisive TrainingDeveloping Integrated Framework for Stress Testing2009Moody’s Analytics Credit Practitioner’s ConferenceLearnings from the CrisisPanel2009IACPM Midwest Regional MeetingConstraints in Managing Capital2009Marcus Evans Capital Allocation ConferenceThe Convergence of Risk Modeling2007Marcus Evans Capital Allocation ConferenceThe Convergence of Risk Modeling
The proposed rule moves supervision from process adherence to demonstrable effectiveness, and explicitly invites experimentation with collaborative and federated machine learning. Why institutions that take up the invitation will examine better than those running isolated systems.
Co-authored with Gary M. Shiffman, co-founder of Consilient, and Shelly Liposky of BMO Capital Markets. How AI can train across many banks’ data without compromising customer privacy — and why that changes the economics of detection.
Money laundering persists because criminals have strong incentives to innovate faster than the institutions detecting them. What that arms race demands of behavior detection.
Longer-form writing on where AI, financial crime compliance, and enterprise risk meet — how regulation, data, models, and technology have to align to support sound decisions.
One idea worked all the way through each week — a short teaser Tuesday, the full framework carousel Thursday. Recent: the three forms of AI risk, and the five AI exposure surfaces.