Kevin Polster is a Manager with Treliant. He has extensive experience in banking, with a focus on financial crimes investigation and regulatory compliance. Kevin brings both analytical and quality control experience in investigations—from inception to law enforcement and
government reporting.

As part of Treliant’s Global Financial Crimes Compliance service area, Kevin has worked with a team handling an ongoing federal monitorship of a top-tier global financial institution on the global audit of its Office of Foreign Assets Control (OFAC) sanctions compliance program. He has also been part of a team that assisted the internal audit group of another large international bank with the execution of all stages of its financial crimes compliance transaction and monitoring audit, including the testing of its effectiveness in meeting terms of a standing Office of the Comptroller of the Currency (OCC) consent order.

Additionally, he has worked with an international bank during all stages of its transaction lookback review, including the analysis of high-risk activity, to meet the terms of a standing written agreement with the Federal Reserve Bank of New York (FRBNY) and New York State

Department of Financial Services (NYDFS). He has also been involved in a wing-to-wing remediation of Bank Secrecy Act/Anti-Money Laundering (BSA/AML) and OFAC issues and a joint federal/state regulator memorandum of understanding (MOU) for a U.S. regional bank.

Prior to joining Treliant, Kevin was an Assistant Vice President and Senior Anti-Money Laundering (AML) Quality Control Analyst at First Niagara Bank. His role involved the filing and reconciling of Suspicious Activity Reports (SARs) to the Financial Crimes Enforcement Network (FinCEN), in addition to staff development through related training programs.

Kevin holds an MBA from Canisius College with a concentration in Financial Services. He is also a graduate of the State University of New York at Buffalo, where he studied Psychology, and is a Certified Anti-Money Laundering Specialist (CAMS).

Areas of Specialization

  • Anti-Money Laundering / Bank Secrecy Act
  • Compliance Audits
  • Compliance Programs
  • Due Diligence
  • Financial Investigations
  • Independent Monitorships and Consultancies
  • Lookbacks
  • OFAC / Economic Sanctions
  • Remediation Plans / Implementation and Effectiveness Testing