Lee Sullenger

About Lee Sullenger

I’m a recognized leader in Digital Assets (DA) and Financial Crimes Compliance (FCC) policy, training, and strategy with more than a dozen years of experience in the AML/CFT space in multiple institutions as an entrepreneur and “intrapreneur” focused on DA, AML risk management, and integration of big data, software tools, and business intelligence into risk decisions and strategies. In my spare time I designed and taught a graduate-level course on cryptocurrencies to MBA students at a private university and launched a crypto-native platform to certify investigators and AML risk managers focused on DA.

Experience

1. Director, Financial Crimes Compliance (Digital Assets)

   BNY

   Apr 2024 — Present · US

   Roles: As the Director for all FCC risks related to DA (crypto, stablecoin, tokenization, etc.) for this Globally-Systematicall Important Bank (G-SIB), I manage and advise on DA AML/Sanctions risk in three principal lines of effort: • Grow & Protect: In the process of onboarding DA and DA-adjacent clients (VASPs, exchanges, OTC/liquidity desks, stablecoin issuers, etc.), I review business models, funds flows, collected KYC documentation and AML/Sanctions risk management P&P and capabilities of FI (US and non-US Banks), NBFI (MSB and Fintechs), funds, as well as HNWI and institutions with novel or unique DA FCC risks. My judgements and advice regarding “fit” with Risk Appetite and Bank brand are used to guide business and compliance decisions to onboard new or retain existing clients. • Build Smartly: As the Bank endeavors to add to DA-related offerings, I provide FCC-related oversight and advice to the development process from ideation to deployment. Key to this process is early identification of risks, required FCC controls, and likely effects on commercial considerations.• Sustain & Defend: As the FCC oversight for all live DA products and services, I advise on team, tools, and training necessary to support integration of blockchain analytics transaction monitoring, travel rule, holistic monitoring, and related detective and preventive controls with the Bank’s existing framework. This is a continuous and risk-based process for every new DA-related product and service with the pace of evolution and integration dependent on product features, engineering capacity, a realistic understanding AML/Sanctions risk, and regulatory expectations.(Personal note: This stage is the sine qua non of being in this space… it is the make-or-break.)

Education

• University of Pittsburgh

  BA, Political Science/Latin American Studies

  1991 — 1995

• Command and General Staff College

  Intermediate Level Education (MEL 4), Military Power at the Operational and Tactical Levels

  2010 — 2010

• Defense Language Institute Foreign Language Center

  Graduate, Korean Language and Literature

  1987 — 1988