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Barry Koch

Barry Koch

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.

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:

  • Global Head of Anti-Money Laundering: American Express Company
  • Senior Vice President: Risk Management & Investigations: Charles Schwab & Co.
  • Senior Vice President: AML, Sanctions, and FCPA Compliance: Smith Barney
  • Deputy Commissioner/General Counsel: NYC Commission for the UN and Consular Corps
  • Second Vice President and Associate Counsel: The Chase Manhattan Bank, N.A.
  • Corporate Attorney: Skadden, Arps, Slate, Meagher & Flom

Barry is a consultant and subject matter expert in these Practice Areas and Services:



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


  • Current Chairman of the Advisory Board of the Association of Certified Financial Crime Specialists (“ACFCS”).
  • Co-founder of the U.S. and EU Bankers’ Alliances Against Human Trafficking.
  • Served as Co-Chairman of the New York chapter of the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) and as a member of the ACAMS Advisory Board.
  • Served as Chairman of the New York State Bar Association’s Committee on the United Nations and Other International Organizations.
  • Served as Chairman of The Consular Law Society, Inc. and as Legal Counsel to The Society of Foreign Consuls in New York.
  • Was an active participant in industry groups such as the Wolfsberg Forum, an association of thirteen global banks which develops frameworks and guidance for the management of financial crime risks, particularly with respect to AML, Sanctions and Counter-Terrorist Financing policies.
  • Was an active participant in the New York Clearing House, SIFMA, and American Bankers Association AML Committees, particularly with respect to the submission to FinCEN of industry comment letters on proposed regulations. The Clearinghouse, which is owned by the world’s largest commercial banks, provides payment, clearing, and settlement services to its member banks and other financial institutions, clearing almost $2 trillion daily and representing nearly half of the automated-clearing-house, funds-transfer, and check-image payments made in the United States. SIFMA, the Securities Industry and Financial Markets Association, is an industry trade group representing securities firms, banks, and asset management companies.


  • Certified Anti-Money Laundering Specialist, CAMS
  • Certified Financial Crime SpecialistCFCS
  • Series 3, 7, 63 and 65


Human Rights Sample

  • Customer and Financial Transaction Traits that May Present Risk for Human Trafficking at the Not for Sale—Joining Forces Against Trafficking in Human Beings conference convened by the Council of Europe and the OSCE.
  • Breaking the Financial Chains: Disrupting Financial Flows Associated with Slavery, Human Trafficking, Forced Labour and Child Labour, United Nations University.
  • Identifying a Financial Footprint of Human Trafficking, United States House of Representatives, Subcommittee on Terrorism, and Illicit Finance.
  • Investigating and Prosecuting Sex Trafficking: A Collaborative Approach, hosted by the New York County District Attorney’s Office and the John Jay College of Criminal Justice.
  • Identifying a Financial Footprint of Human Trafficking, at the National Association of Attorneys General Presidential Initiative Summit—Pillars of Hope: Attorneys General United Against Human Trafficking.
  • Combating the Commercial Sexual Exploitation and Sex Trafficking of Minors, hosted by the Institute of Medicine of the National Academies.
  • Identifying a Financial Footprint of Human Trafficking, at the Trust Women: Putting the Rule of Law Behind Women’s Rights conference sponsored by the Thomson Reuters Foundation and the International Herald Tribune.
  • Mt. Sinai Hospital Department of Pediatrics’ Conferences on Child Abuse and Neglect and Commercial Sexual Exploitation and Sex Trafficking of Minors.
  • Human Trafficking: Customer and Financial Transaction Traits that May Present Risk at the Human Rights Summit sponsored by Human Rights First.
  • Identifying a Financial Footprint of Human Trafficking, at the 2015 Annual Meeting of the Conference of Western Attorneys General.
  • Increasing the Role of the Financial Services Industry in Combatting Human Trafficking, at the Fifth Annual Cook County Human Trafficking Task Force Conference.
  • Cross-Disciplinary Solutions to Human Trafficking, Texas Christian University Symposium on Modern Slavery and Human Trafficking.

Anti-Money Laundering and Financial Crime Sample

  • Presented the Advanced SAR sessions at the United States Department of Justice’s national training center for Federal law enforcement.
  • Delivered AML compliance training to the Criminal Division of the Internal Revenue Service and to the New York field office of the Department of Homeland Security.
  • Presented Crisis Management and Reaction to Breaking Events at SIFMA Annual Meeting (2017).
  • Principal architect of the financial industry’s partnership with the United States Treasury Department’s Private Sector Dialog at the PSD’s inception, delivering numerous presentations to senior bankers, government officials, and Compliance officers in the Middle East, North Africa, Latin America, and Europe, on US regulation of correspondent banking.
  • AML presentations at annual meetings of the American Bankers Association/American Bar Association; Securities Industry and Financial Markets Association; ACAMS; ACFCS; Southwest Border Anti-Money Laundering Alliance; Mid-Atlantic Anti-Money Laundering Conference.

Contact Bates Group

Bates Group is with you every step of the way. Contact us today for more information on how our End-to-End Solutions can help your firm.