Columbia Law School

University of Stockholm (Sweden)

Yale University

Director, Associate General Counsel, the Americas

Skills: Global Regulatory Compliance · Risk Management · Communication · Advertising · Legal Compliance · Retail Banking · Regulatory Agencies · Privacy Compliance · Privacy Regulations · OFAC · Compliance Assurance · Risk Assessment · Sanction · Consumer Law · Regulatory Strategy · Public Speaking · Regulations · Legal Writing · Corporate Law · Legal Advice · Mobile Payments · Payments · Corporate Governance · Financial Institutions · Financial Services · Banking · Credit Cards

StellarFi 🚀

General Counsel & Director of Compliance

Skills: Global Regulatory Compliance · Communication · Advertising · Legal Compliance · Retail Banking · Regulatory Agencies · Privacy Compliance · Privacy Regulations · OFAC · Compliance Assurance · Risk Assessment · Sanction · Consumer Law · Regulatory Strategy · Regulations · Analytical Skills · Legal Writing · Corporate Law · Legal Advice · Mobile Payments · Payments · Banking Law · Corporate Governance · Financial Institutions · Financial Services · Banking · Credit Cards

The Law Office of Marilyn D Barker

Principal Owner

-Establish WorldRemit’s legal and regulatory infrastructure for the US and the Americas
-Manage day-to-day legal operations in the US and broader Americas as primary point of contact
-Manage day-to-day legal matters arising from US, Canadian and Latin American operations, as well as managing the regulatory licensing and consent processes for the US and the Americas
-Advise on US state money transmitter laws and both federal and state consumer protection laws
-Assist in the preparation for and advise on regulatory examinations
-Advise on regulatory strategy, including horizon-scanning of legal and regulatory developments, conducting impact assessments and communicating change management
-Provide commercial and solutions focused regulatory advice to senior executives within the business, including for product launches, product development and geographic expansion
-Anticipate, identify and escalate legal and regulatory issues of concern
-Implement regulatory change and support the delivery of strategic projects
-Perform job function autonomously and as part of an international, cross-functional team
-Educate and train internal stakeholders and other team members 
-Contribute to team development to scale efficiency and improvement
-Build and manage relationships with external stakeholders, including regulators, governments and external counsel
-Advise on and negotiate a wide range of commercial agreements relating to the commercial operations of the Americas (such as customer terms and conditions, privacy standards, network arrangements, commercial partnerships and service provider contracts, including signing off marketing content, with support from the wider team as needed)

WorldRemit

Associate General Counsel, the Americas

General Counsel
Conotoxia, Inc.
3/2019 – Present

The FinTech Conotoxia, Inc., offers, via its online platform and through its mobile app, money remittance and payments services to the European Economic Area in 26 different currencies.  Conotoxia is the U.S. subsidiary of its Polish financial services company parent, Conotoxia Holdings Group.  The Group, through its Polish subsidiary, Cinkciarz, has processed over $15 billion in transaction volume to date. 

Responsibilities: 
-Build out company’s U.S. legal infrastructure and manage company’s day-to-day legal operations 
-Engage in legal and regulatory strategic planning efforts
-Advise company on emerging payments, financial services, treasury management and banking issues, as well as legal and regulatory status of products and services offered by company
-Develop and implement governance related management information systems and protocols
-Manage and coordinate the submission of state money transmitter applications
-Draft and negotiate various contracts and agreements for ordinary and extraordinary corporate activities
-Serve as subject matter expert on AML, sanctions-related and privacy (GLBA, GDPR) regulatory compliance matters   
-Coordinate and manage outside counsel workflows
-Assist in the coordination of regulatory examinations and independent regulatory reviews of operations   
-Draft policies, procedures, processes and controls for effective implementation of enterprise-wide legal and regulatory initiatives 
-Track emerging legal and regulatory developments impactful on U.S. operations
-Support Human Resources related efforts

Conotoxia, Inc. (subsidiary of Conotoxia Holding, Poland)

General Counsel

-Manage day-to-day legal and compliance operations of global financial services holding company and its international subsidiaries.  
-Remediate and implement enterprise-wide regulatory compliance program with special focus on anti-money laundering (AML), counter-terrorism financing (CTF) and Sanctions compliance.  
-Serve as subject matter expert on AML, CTF and Sanctions-related regulatory compliance.  
-Coordinate regulatory examinations and independent regulatory reviews of operations.  
-Report periodically to the Board and senior management on compliance initiatives and results. 
-Draft policies, procedures, processes and controls for effective implementation of enterprise-wide compliance program.
-Draft various agreements for ordinary and extraordinary corporate activities.  
-Coordinate and manage outside counsel workflows.  
-Track emerging legal and regulatory developments impactful on the enterprise.

Es Solo

General Counsel/Global Chief Compliance Officer

-Establish and implement U.S. compliance infrastructure.
-Counsel on MSB state licensing requirements.
-Obtain and maintain money transmitter licenses.  
-Lead and coordinate onsite state and federal regulatory examinations and audits in support of independent reviews and partner due diligence. 
-Negotiate and draft corporate contracts involving bank partners, payment processors, merchants and third party vendors and service providers.
-Draft various other corporate contracts, terms and conditions, as well as nondisclosure and confidentiality agreements, controlling for privacy (GLBA and Privacy Shield), Regulation E and UDAP/UDAAP related disclosure issues.
-Provide strategic guidance on legal and compliance risks, business strategies and other issues related to commercial transactions and general operations involving merchant payment processing and in network remittance transfers.
-Assist in product development and implementation from a U.S. compliance perspective.
-Draft and implement compliance related policies, procedures, processes and programs.
-Oversee and supervise day-to-day implementation of the BSA/AML/Sanctions (OFAC) compliance program. 
-Conduct training for board, senior management and staff principally on BSA/AML/Sanctions(OFAC), as well as other compliance legal and regulatory matters.

SEQR Payments, Inc. (subsidiary of Seamless Distribution Systems, Sweden)

Chief Compliance Officer, U.S.

-Responsible for the establishment and maintenance of a robust BSA/AML/OFAC (sanctions) risk program (Program) in the U.S. for equipment leasing subsidiary of global banking organization.
-Participate in all relevant regulatory examinations and internal audits, including addressing all findings and recommendations.
-Responsible for defining and managing the Program including risk assessment and related methodology, 	governance processes and action or project management plan(s).
-Oversee the development of and updates to the BSA/AML/OFAC risk assessments.
-Promote the Program, including ownership of obligations, establishing and maintaining a compliance framework, serving as subject matter expert on projects evaluating compliance requirements and 	compliance training.
-Enhance management information and reporting to enable effective oversight of the applicable committee in both the United States and the Netherlands.
-Collaborates with DLL Global Compliance to establish global standards for money laundering, anti-terrorist financing or other financial crime and to establish global and regional alignment.
-Monitor changes in laws, rules and regulations relating to BSA/AML/OFAC risk management and work with Legal to interpret such changes.
-Draft policies, procedures, controls and processes in support of the Program. 
-Draft BSA/AML/OFAC and other financial crime training materials and conduct training.

DLL (subsidiary of Rabobank, Netherlands)

BSA/AML/OFAC Officer/Deputy Chief Compliance Officer, North America/Outside Counsel/Consultant

-Provided, as Assistant General Counsel and then as Chief Regulatory Counsel, strategic guidance for the legal and regulatory affairs of a multi-billion dollar banking organization.
-Served as Director of AML/OFAC Risk Management, remediating and overseeing AML/OFAC compliance program, and then consulted in this functional area.  
-Directly managed AML/OFAC risk management compliance staff.  
-Advised and counseled Senior Management Team and Business Units Leaders (collectively, “Clients”) on new products, services, operational practices on associated legal and regulatory risks.
-Partnered with Business Unit (or Line of Business) Leaders and collaborated with the Bank’s Compliance and Third Party Risk Management staff on legal, regulatory and compliance matters in connection with the implementation of the Bank’s enterprise risk management programs or other initiatives of the Bank.
-Advised specifically on BSA/AML/OFAC, UDAP/UDAAP, EFTA, TILA, FCRA, Card Association rules, and abandoned property related risk management and compliance functions.	  
-Drafted, reviewed, interpreted and negotiated complex commercial contracts on behalf of Clients consistent with the Bank’s policies, procedures, and applicable law and regulation.
-Interpreted -- in a rapidly changing regulatory landscape -- statutes, regulations and supervisory guidance applicable to the Bank’s business activities and maintained a working knowledge of federal banking laws and regulations. Proactively assessed any emerging legal and regulatory risks presented by current or proposed changes in the law or industry guidance.
-Monitored regulatory and case law developments to assess impact on the Bank’s compliance processes.  Provided practical and accurate oral and written updates and/or training to impacted Clients and their staff as appropriate.  Drafted comment letters discussing potential impact of rulemaking proposals.  Participated in trade association activities.

The Bancorp, Inc.

Various Titles  Senior Vice President, Assistant General Counsel, Regulatory Counsel

Represent various financial services, prepaid card, mobile, e-commerce, and remittance and MSB clients in connection with their state and federal regulatory compliance obligations, including related BSA/AML/OFAC, abandoned property, state licensing and consumer protection requirements.

Principal

-Provided AML, OFAC, state licensing and other legal counseling to financial services companies, including prepaid, remittance, payments and other money services businesses.

Bryan Cave LLP

Counsel

-Participated on leadership teams to (i) develop and formulate regulatory framework under the BSA for stored-value products and money services businesses; (ii) draft BSA regulations requiring SEC-registered investment advisers, commodity trading advisors, commodity pool operators and unregistered investment companies to establish AML programs; (iii) draft FinCEN’s contribution to the National Money Laundering Strategy; as well as (iv) draft FinCEN’s ongoing strategy on stored value and money services businesses issues. 
-Served as Coordinator (or Team Leader) for the Office of Regulatory Policy for money services businesses and stored value products projects.
Provided BSA interpretative guidance to Treasury officials, various financial institutions industry segments subject to BSA regulation, as well as other federal and state regulatory and law enforcement authorities. 
-Drafted administrative rulings and other written interpretative guidance. 
-Ensured that interpretative guidance and administrative rulings and other written products produced and issued by the Office of Regulatory Policy conform to existing agency BSA interpretative guidance. 
-Provided training and outreach to foreign delegations on the structure and function of the U.S. BSA legal and regulatory regime.
-Served as a U.S. delegate to the Financial Action Task Force (FATF) and Asia-Pacific Economic Cooperation’s (APEC) Counter-Terrorism Financing Workshop held in Melbourne, Australia.
-Served as FinCEN’s representative to interagency working groups on Bank Fraud and CyberFraud.

Marilyn Barker