Robert Pasley

Robert Pasley, CAMS, J.D. is an expert in anti-money laundering as well as financial regulatory and enforcement matters. Robert has over 35 years of experience and is a specialist in bank regulatory and enforcement issues, BSA, AML, and counter-terrorism financing. From 1975 to 2005, Robert served first as an attorney and then as an assistant director of the Enforcement and Compliance Division at the Office of the Comptroller of the Currency (OCC). At the OCC, Robert was responsible for investigating as well as taking and/or supervising administrative actions against national banks and their officers and directors. Additionally, he served as the point person on anti-money laundering cases.

Robert helped to draft BSA regulations, including those implementing §312 of the USA PATRIOT Act addressing foreign correspondent banking and foreign private banking. He also handled the investigation of and administrative action against foreign branches. Robert has been a consultant for the International Monetary Fund, American Express, the Financial Crimes Enforcement Network (FinCEN), the law firm of Bryan Cave, and the American Bankers Association (ABA). Previously, he was a senior vice president at Bank of America. He also served as the acting general counsel for the District of Columbia’s Office of Banking and Financial Institutions and as a special assistant U.S. Attorney for Washington D.C.’s U.S. Attorney’s Office.

Robert received his BA from Hamilton College and his JD from Cornell Law School. He also graduated from the Stonier Graduate School of Banking with an Honors Thesis on the “Consolidation of the Federal Banking Regulatory Agencies”.


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