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Mr. Koch is a Bates Consulting Expert in the fields of anti-money laundering and sanctions compliance, anti-bribery and corruption investigations, and global financial crime risk management. An independent consultant, former prosecutor, and experienced arbitrator in the securities/investment industry, he has for more than 20 years designed, implemented and managed complex global compliance programs (including related technology solutions) for some of the world’s largest and best-known financial institutions, gaining expertise in correspondent, commercial, consumer and private banking; money transmission; credit cards and merchant acquiring; money services businesses; and in the securities industry.
In his current consulting and legal practice, he provides Expert Witness, independent testing (audit), and compliance and legal advisory services to governments, international arbitration tribunals, regulatory agencies, financial institutions, private equity firms, family offices (wealth management) and international law firms. He is a co-founder of the U.S. and European Bankers’ Alliances Against Human Trafficking, is a member of the McCain Institute’s Anti-Human Trafficking Ambassadors Group and is a Commissioner on the United Nations Financial Sector Commission on Modern Slavery and Human Trafficking.
He enjoys an excellent reputation with banking regulators and law enforcement agencies around the globe and has assisted numerous financial institutions in successfully completing their remediation commitments under various Written Agreements with U.S. and foreign regulators. A sought-after speaker at industry, government, and law enforcement conferences, he has presented to groups including the United States Departments of Justice, Homeland Security, State and Treasury; the IRS and DEA; members of the intelligence and diplomatic communities; Congressional subcommittees considering proposed AML legislation; and regulators, legislators, international organizations, and Financial Intelligence Units on six continents. He has represented several financial institutions on FinCEN’s Bank Secrecy Act Advisory Group (“BSAAG”), created by Congress to advise the Secretary of the Treasury on BSA issues.
RELEVANT POSITIONS
Mr. Koch most recently served as an Assistant District Attorney and Counsel to the Investigation Division in the New York County District Attorney’s Office. The Investigation Division included the Major Economic Crimes, Cybercrime, Public Corruption, Fraud, Tax, Asset Forfeiture, and Counterterrorism Bureaus, as well as the International Money Movement Center and Financial Intelligence Unit.
Prior to joining the DA’s Office, Mr. Koch was the Chief Compliance Officer of Western Union, where he managed a global department of more than 2,100 professionals with an annual budget of $215 million, responsible for Anti-Money Laundering and Sanctions Compliance; Consumer Protection and Fraud Risk Management; Global Security; Internal Testing; Systems & Analytics; Training; Licensing and Regulatory Exams; Project Management; and Risk Assessments. He was a member of the Supervisory Board of Western Union International Bank GmbH, an Austrian bank licensed by the Finanzmarktaufsicht.
Mr. Koch was previously a Managing Director and Associate General Counsel at JPMorgan Chase, where he served for five years as the legal counsel for JPMC’s global anti-money laundering compliance program. In that capacity, he handled issues related to complex criminal investigations and subpoena compliance; preparation and filing of Suspicious Activity Reports; and cases involving sanctions violations, fraud and cyber-crime, corruption and organized crime, human trafficking, terrorist financing, Black Market Peso Exchange and drug money laundering. He worked closely with JPMC’s Financial Intelligence Unit to develop A Financial Footprint of Human Trafficking, which served as a catalyst for the formation of the U.S. and European Bankers’ Alliances Against Trafficking.
His prior legal and compliance experience includes:
Bates Group LLC, Consulting Expert, 2017 - Present
New York County District Attorney’s Office, Assistant District Attorney/Counsel to the Investigation Division, 2015-2016
Western Union, Chief Compliance Officer, 2013-2015
JPMorgan Chase, Managing Director and Associate General Counsel, 2008-2013
American Express Company, Global Head of Anti-Money Laundering, 2002-2008
Charles Schwab & Co., Senior Vice President, Risk Management & Investigations, 2001-2002
Smith Barney, Senior Vice President, Head of AML Compliance, 1994-2001
New York City Commission for the United Nations and Consular Corps, Deputy Commissioner/General Counsel, 1985-1994
Juris Doctor (JD), New York University School of Law
Bachelor of Arts (BA), magna cum laude, University at Albany, SUNY
Human Rights Sample
Anti-Money Laundering and Financial Crime Sample