Shaun Creegan

Shaun is a Managing Director within Protiviti's Risk & Compliance practice focused on regulatory matters for Financial Services Institutions. Shaun has a subject matter expertise in Anti-Money Laundering and Sanctions compliance. He has performed extensive work with top tier financial institutions to address regulatory enforcement actions and improve AML operations during his 8+ years at Protiviti. Most recently Shaun was a Managing Director and Global Head of AML and Sanctions Audit at Citi. In that role, he provided oversight, direction, subject matter expertise, and regulatory assurance for Citi’s Global AML and Sanctions Audit Programme. He was responsible for delivering a global AML and Sanctions audit plan, performing validation for the firm's AML consent orders, and leading interactions with Citi’s various regulators. Previously, Shaun spent 6 years in Internal Audit at Morgan Stanley and Lehman Brothers covering various aspects of their businesses’ including Retail, Institutional, and Advisory Services.

Selected Projects

• Lead a team of 80+ resources on an AML consent order remediation engagement for a top 5 international financial institution. Engaged by the institution’s Internal Audit department to: create remediation plans to address consent order requirements; develop a global AML Audit Programme; improve their audit risk assessment methodology and audit planning process; enhance senior management reporting; enhance their sampling approach and risk-based testing procedures; perform Skills and Capacity Staffing analysis of Audit resources; and provide overall project management of Audit’s validation efforts.
• Managed AML audits reviews for different types of financial institutions including: top tier domestic and international banks, regional and community banks, broker/dealers, investment companies and trust companies. These reviews were designed to help ensure compliance with the requirements of Section 352 of the USA PATRIOT Act, OFAC/global sanctions requirements, the institutions’ BSA/AML policies and procedures as well as the expectations of the institutions’ regulators.
• Performed Lookback investigations for multiple international banks. These reviews included transactional analysis and enhanced due diligence to identify questionable and/or suspicious activity. Prepared escalation referrals and reviewed SARs filed by the bank to determine adequacy and accuracy of the information. 
• Managed a large scale OFAC investigation for a large international bank. Researched transactional activity for possible OFAC and global sanctions violations including potential hits against governmental sanctions lists and alterations of transactions to avoid reporting requirements.
• Managed a large scale KYC re-documentation project where the institution had to re-perform KYC and due diligence on their customer base.
• Conducted a Gap Analysis comparing an institution’s AML Programme to the regulatory requirements (BSA, USA PATRIOT Act, OFAC) and leading industry practices.
• Reviewed several institutions’ AML transaction monitoring systems. Evaluated the effectiveness and appropriateness of transaction monitoring rules utilised by the institution. Reviewed the SAR reporting procedures.
• Developed/updated AML and global sanctions policies and procedures for several financial institutions.
• Managed several compliance reviews for Broker-Dealers and Investment Advisers clients. These reviews have included: Policies and Procedures, Compliance Oversight, Supervision, Reporting, Annual Compliance Requirements, Insider Trading and Sales Practices.
• Managed several Front Office and Operational reviews for Broker-Dealers. These reviews have included: end to end trading, specific trading desk reviews, accounting, treasury, human resources, and operations. Specific tasks of these projects include: reviewing and analysing the company’s policies and procedures, interviewing management, identifying risks and controls, testing of controls, and communicating areas of improvement to management.

Areas of Expertise

• Regulatory Risk
• Anti-Money Laundering
• Office of Foreign Assets Control (OFAC)
• Compliance
• Internal Audit

Industry Expertise

• Financial Services

Education

• B.S. – Applied Economics & Business Management, Cornell University

Professional Memberships and Certifications

• Previously Series 7 & 66 registered
• Risk Management Association
• Institution of Internal Audits
• Anti-Money Laundering Professional (AMLP)
• ACAMS