Spencer Schulten is a Managing Director for Global Financial Crimes Compliance at Treliant. As a seasoned compliance executive with more than 16 years of experience as a regulator, lawyer, and consultant, Spencer focuses on Bank Secrecy Act/Anti-Money Laundering (BSA/AML) and sanctions matters for financial institutions of all sizes and risk profiles. He also assists clients with matters pertaining to the Investment Company Act of 1940 (“Company Act”), Investment Advisers Act of 1940 (“Advisers Act”), and derivatives compliance.
Spencer began his career with the US Securities and Exchange Commission (SEC) and in market regulation with the Financial Industry Regulatory Authority (FINRA) before joining Apollo Global Management, Inc. as a compliance officer and counsel. Prior to joining Treliant, he held various senior advisory positions within the Big Four accounting firms and served for the past three years as an Executive Director and US Head of Financial Crimes Compliance for Capco, a global consultancy focused on financial services.
His career experience has included the following:
- Conducting BSA/AML program reviews for domestic financial institutions and foreign banking organizations.
- Coordinating BSA/AML compliance action plans and related regulatory responses pursuant to consent orders and Acceptance, Waiver, and Consent (AWC) letters.
- Managing several global banking institutions’ responses to a Federal Reserve Board cease and desist order.
- Conducting large historical transaction reviews (“lookbacks”) for several large banking entities and broker-dealers in response to regulatory findings and self-reported BSA/AML and sanctions compliance failures.
- Designing and executing global BSA/AML and sanctions risk assessments for large domestic and foreign banking organizations.
- Designing a BSA/AML compliance process for a large bank’s migration to an online banking platform.
- Conducting a Security-Based Swap Dealer (SBSD) impact analysis for two global banking institutions.
- Designing a large banking institution’s global compliance structure.
- Advising several global financial institutions during the implementation of an enhanced Volcker Rule compliance program.
- Advising a global investment banking institution during implementation of OTC Derivative reforms required by Title VII of the Dodd-Frank Reform Act.
Spencer is a graduate of Trinity College (CT), the University of Miami and the Georgetown University Law Center. He is a Certified Anti-Money Laundering Specialist (CAMS) and is admitted to the bars of the State of New York and the U.S. Supreme Court. During law school, Spencer held a summer clerkship with the Honorable Steven D. Merryday, U.S. District Judge for the Middle District of Florida.
Areas of Specialization
- Anti-Money Laundering / Bank Secrecy Act
- Bank Management
- Compliance Programs
- Executive Leadership
- Financial Investigations
- FinTech Compliance
- Independent Monitorships and Consultancies
- Litigation Support / Expert Witness Testimony
- Model Validation
- OFAC / Economic Sanctions
- Office of the General Counsel
- Project Management
- Regulatory Exam / Management
- Regulatory Relations
- Remediation Plans / Implementation and Effectiveness Testing
- Risk Assessments