Nicolas Grabowski

About Nicolas Grabowski

I am a licensed attorney working at the intersection of financial crime compliance, AI/ML model governance, and regulatory risk management in financial services.At Deutsche Bank, I sit within the Chief Risk Office conducting second-line oversight and effective challenge of AFC and compliance models — including transaction monitoring systems, sanctions screening tools, named entity recognition, and KYC-related AI/ML applications. My work focuses on governance defensibility, regulatory examination readiness, model documentation quality, and translating complex technical systems into risk decisions that hold up to scrutiny.Before Deutsche Bank, I worked as an AML/BSA Compliance Officer at Safra National Bank, giving me direct first-line operational context that informs how I approach second-line challenge.My legal training, compliance operations background, and model governance experience sit at a niche intersection that is increasingly relevant as regulators intensify focus on AI use in financial crime compliance. I think carefully about how institutions govern, document, and defend the systems they rely on — and how the regulatory environment around those systems is evolving.I am selectively exploring opportunities in compliance counsel, regulatory counsel, AFC legal, and AI governance roles where this combination creates immediate value.

Experience

1. Ai Ml Model Risk & Governance Officer Attorney (Ny)

   Deutsche Bank

   Aug 2024 — Present · New York, NY, US

   New York-licensed attorney conducting second-line oversight and effective challenge of AI/ML, generative AI, and financial crime models within Deutsche Bank’s Chief Risk Office – Model Risk Americas. One of a small number of practitioners to have formally governed production generative AI systems — including an internal LLM-based Compliance Digital Assistant and Document AI built on Google Gemini — in a regulated financial services context.Model portfolio spans sanctions and embargoes screening, AML/CTF, transaction monitoring, chain analysis, NLP, NER, and NLS surveillance models, personal account dealing activity, suitability and appropriateness trade oversight, gifts and entertainment compliance, FERCO soft models, internal claims policy compliance, and CCAR and stress testing models. Conduct full annual review cycles across the entire model portfolio.Translate SR 11-7, OCC 2011-12, FRB guidance, and emerging AI/ML regulatory standards into defensible governance frameworks, risk decisions, and examination-ready documentation. Developed “best available technology” governance framework subsequently adopted across Deutsche Bank’s Legal, AFC, and Chief Risk Office functions.Apply legal training to assess documentation quality, model limitations, privacy and data-use risk, sanctions and AML implications, and interpretive regulatory exposure — bridging technical model review and legal risk analysis in a way pure quantitative reviewers cannot.Advise Legal, AFC, Compliance, Engineering, and Data Science on model risk, AI governance, exam readiness, and interpretive regulatory questions. Author validation reports, MDDs, adverse finding reports, ALWs, and responsible AI narratives. Manage 4C model identification, annual review cycles, inventory accuracy, and lifecycle governance documentation. Deliver internal training on SR 11-7, AI/ML governance, explainability, and responsible AI frameworks.

Education

• University of Central Florida

  Bachelor of Arts - BA, Political Science

  2016 — 2018

• Barry University - Dwayne O. Andreas School of Law

  Doctor of Law - JD, Law

  2018 — 2021