Richard A. Lani

Directed the AML compliance program for a global precious metals refiner. Deployed due-diligence processes to detect suspicious activity including large cash transactions, unusual sources of funds, wire transfers, and politically exposed persons (PEPs). Built the organization's AML policy and procedure framework and internal controls, and maintained all required records and documentation.

Built and led RMC's Compliance Department, developing and implementing the firm's AML program, client Risk Matrix, Anti-Bribery, Anti-Corruption, Ethics, and Supply Chain Management policies. Approved and filed SARs with FinCEN. Was instrumental in obtaining COMEX Silver Good Delivery status, LBMA Gold and Silver Good Delivery certification, and Responsible Jewelry Council (RJC) conflict-free refiner certification. Traveled extensively across Latin America to vet gold mines as part of responsible sourcing and supply-chain due diligence.

Served on the Executive team, directing all Compliance, AML, and regulatory reporting functions under CFTC, NFA, Dodd-Frank, BSA, OFAC, and Patriot Act requirements. Advised the Global Board of Directors on evolving U.S. regulatory requirements and their impact on business operations.

Founded the firm (originally Compliance Consultant Group) to deliver AML and compliance services to Futures Commission Merchants, Introducing Brokers, and Public Funds. Prepared compliance manuals, AML policies, and disaster recovery plans; managed NFA/CFTC registrations and performed AML, branch/IB, and pre-NFA audits.