David Caruso is a Managing Director with Treliant. Over the past 23 years, he has implemented Anti-Money Laundering (AML) and sanctions compliance programs, led complex financial crime investigations, and built an AML RegTech software company. David has been an AML Officer, Chief Compliance Officer, Partner of an AML consulting firm, and Partner of a successful AML software company. This unique background enables him to provide clients with valuable insight to successfully navigate today’s changing financial crimes compliance environment.

David has extensive experience building suspicious activity monitoring and investigation programs, customer risk rating programs, and due diligence operations. He has built AML operations teams at small, midsize, and large U.S. and international financial institutions.

Prior to joining Treliant, he was the Chief Client Officer of a RegTech software company whose machine intelligence application improved how AML teams search and use adverse media in risk rating, transaction monitoring, and suspicious activity detection.

Previously, David founded and was CEO of an AML consulting firm whose clients included midsize and large U.S. and international financial institutions. He worked alongside AML officers, executive management, and boards solving complex AML problems, leading national and international remediation projects, and working closely with U.S. regulatory agencies.

David was also Chief Compliance and AML Officer at Riggs Bank, where he built a compliance, investigations, and security department in response to an enforcement action. He led the implementation of a new AML program across all U.S. and U.K. business lines. In addition to leading the bank’s efforts to address consent orders by the Office of the Comptroller of the Currency (OCC), Federal Reserve, Federal Deposit Insurance Corporation (FDIC), and the U.K.’s Financial Conduct Authority (FCA), David and his team resolved investigations by the Department of Justice (DOJ) and a U.S. Senate subcommittee into foreign corruption and money laundering.

David’s other positions have included Director at two of the Big Four consulting firms, where he led AML compliance and fraud investigation teams. JP Morgan also hired him to create an AML and enhanced due diligence group. Earlier in his career, David was a U.S. Secret Service Special Agent with the New York Field Office’s Financial Institution Fraud group.

David speaks on AML issues in the U.S., Asia, and Europe; has testified before Congress on Bank Secrecy Act (BSA) policy changes; has taught AML assessment techniques to examiners at the OCC, FDIC, and Federal Reserve; and is often published in financial news journals.

He holds a BA from George Washington University.

Areas of Specialization

  • Anti-Bribery and Corruption
  • Anti-Money Laundering / Bank Secrecy Act
  • Compliance Programs
  • Corporate Investigations
  • Due Diligence
  • Executive Leadership
  • Financial Investigations
  • Fraud Risk Management
  • Government Investigations / Whistleblower Response
  • Litigation Support / Expert Witness Testimony
  • Lookbacks
  • Model Validation
  • OFAC / Economic Sanctions
  • Project Management
  • Regulatory Exam / Management
  • Regulatory Relations
  • Remediation Plans / Implementation and Effectiveness Testing
  • Risk Assessments
  • Strategy / Strategic Planning
  • Third-Party Risk Mitigation