ROSS S. DELSTON, CAMS, CTCE
ATTORNEY + EXPERT WITNESS
WASHINGTON, DC | ST. LOUIS, MO
(202) 494-5835 (O)
(202) 280-1465 (F)
SUMMARY: Attorney, Certified Anti-Money Laundering Specialist (CAMS), Cryptocurrency Tracing Certified Examiner (CTCE) and former US banking regulator (FDIC) with substantial expertise in Anti-Money Laundering (AML) compliance for over 20 years. Expert witness on AML compliance in 21 cases. Participated in two monitorships (BNP Paribas and AIG). .
LAW OFFICE OF ROSS S. DELSTON | WASHINGTON, DC | ST. LOUIS, MO
2006 – PRESENT- Testifying or consulting expert on AML issues in 21 civil and criminal cases in the U.S. and Canada; testified on behalf of plaintiffs in Joint Liquidators of Stanford International Bank v. TD Bank, one of the largest Ponzi schemes in recent decades.
- Participated in BSA/AML compliance project as part of Independent Consultant’s team for BNP Paribas for five-month period ending early 2015. Project involved AML/KYC, trade finance, international banking, and sanctions/OFAC in the U.S. and Europe.
- Assisted Bryan Cave law firm in 15-month project ending July 2008 as part of AIG monitorship: Reviewed AIG’s BSA/AML compliance functions worldwide, analyzed compliance policies, interviewed compliance officers, and drafted recommendations.
- Conductedfive consecutive annual AML reviews for a publicly-held MSB and a review for a smallerMSB with officesthroughout the Washington, DC area.
- Retained by financial regulator of major offshore financial center (OFC) to conduct a review of its AML/CFT compliance activities as well as those of the regulated sector.
- Consultant to IMF since 1997 and participated in nine AML/CFT assessments of OFCs; draft legislation on AML/CFT and banking regulation for numerous countries.
- Consultant to World Bank1998 - 2014 on banking issues.
MANAGING DIRECTOR, KALORAMA PARTNERS, WASHINGTON, DC
2005 – 2006- Advised financial services firms on compliance issues as a member of strategic consulting firm headed by former SEC Chairman Harvey Pitt.
- Consultant to Kalorama on review of compliance program for broker-dealer to
ensure consistency with NYSE and NASD requirements, October 2005.
LEGAL DEPARTMENT, INTERNATIONAL MONETARY FUND, WASHINGTON, DC
Consulting Counsel (full-time) specializing in AML/CFT
2000 – 2005Legal Consultant (project basis) on banking laws
1997 – 2000
- OFC Coordinator: Designated by General Counsel to coordinate legal team during
initial phase of OFC assessment program, July – January 2000. - AML/CFT assessments: Participated in assessments of seven OFCs.
- Legislative drafting: Drafted laws on AML/CFT and banking for numerous countries.
- Training: Organized, moderated and/or spoke at numerous legislative drafting workshops for government officialsand bankers on implementing AML/CFT standards.
LAW OFFICE OF ROSS S. DELSTON, WASHINGTON, DC
1994 – 2000- Specialized in bank regulatory and transactional matters for clients such as a Fortune 50 industrial corporation, a major commercial bank, and an S&L holding company.
- Reviewed US government agency proposal for AML compliance and OFAC program.
OF COUNSEL, JONES DAY, WASHINGTON, DC
1991 – 1994- Specialized in bank mergers and acquisitions and regulatory matters.
- Represented a money-center bank in successful bid on an insolvent bank controlled
by the FDIC, and a consumer finance firm in licensing an industrial loan company. - Testified on open bank assistance before RTC Oversight Board.
COUNSEL AND ASSISTANT GENERAL COUNSEL – ASSISTED ACQUISITIONS,
LEGAL DEPARTMENT, FEDERAL DEPOSIT INSURANCE CORP., WASHINGTON, DC
1986 – 1991- Created, organized and headed 20-attorney Assisted Acquisitions unit, advised
FDIC Chairman and Board, led teams responsible for drafting and negotiating deal documents, hired and supervised outside counsel, and implemented training. - Responsible for the legal work on resolutions of major insolvent banks during US banking crisis, including open bank assistance and bridge bank transactions for virtually every major bank failure during that period.
COUNSEL, EXPORT-IMPORT BANK OF THE US, WASHINGTON, DC
1976 – 1986- Drafted and negotiated numerous loan, guarantee, and insurance transactions.
- Lead attorney on a $1.5 billion emergency trade credit facility for Brazil, at
that time the largest commitment ever authorized by the Export-Import Bank. - Traveled to Nigeria, Ivory Coast, Senegal, Ecuador, and Bolivia to assess projects.
MEMBERSHIPS,CERTIFICATIONS, & AFFILIATIONS
- District of Columbia Bar Association, 1977 – present.
- Certified Anti-Money Laundering Specialist (CAMS), 2007 – present.
- Certified CAMS Trainer, 2010 – present.
- Certified CipherTrace Examiner (CTCE), 2020 – present.
- AV Preeminent rating by Martindale-Hubbell Directory (highest rating), 1996 – present.
- International Editorial Board, Journal of Banking Regulation (London), 2004 – present.
- Board of Advisors, Global South Dialogue on Economic Crime, 2021 – present.
- Distinguished Lecturer, Executive M.A. in Financial Integrity Program, Case Western Reserve University School of Law, January 2016 - present. For more information, please see https://law.case.edu/Academics/Degrees/Master-of-Arts-in-Financial-Integrity
- Founding board member, US Capital Chapter of Association of Certified Anti-MoneyLaundering Specialists (ACAMS), 2009 – 2011; Advisor to Board, 2011 – 2013.
- Co-chaired American Bar Association International AML Committee, 2008 – 2011.
EDUCATION
The GeorgeWashingtonUniversityLawSchool, J.D. with honors, 1976.
The GeorgeWashingtonUniversity, B.A. with Special Honors, 1973.