Mr. Koch is an independent consultant with Bates Group and a private attorney who is recognized internationally as an expert in the field of anti-money laundering compliance and risk management. 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 includes the Major Economic Crimes, Cybercrime, Rackets, Fraud, Tax, Asset Forfeiture, Corruption and Counterterrorism Bureaus, as well as the International Money Movement Center and Financial Intelligence Unit.
Prior to joining the DA’s Office in November 2015, 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 AML/BSA/OFAC; Consumer Protection and Fraud Risk Management; Global Security; Internal Testing; Systems & Analytics; Training; Licensing and Regulatory Exams; Project Management; and Risk Assessments.
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; and cases involving Black Market Peso Exchange, human trafficking, corruption and organized crime, terrorist financing and drug money laundering.
With extensive investigative and legal experience in money laundering and terrorist financing cases, he is a sought-after speaker at industry, government and law enforcement conferences, having presented to groups including the United States Department of Justice; the Departments of Homeland Security, State and Treasury; the IRS and DEA; members of the intelligence and diplomatic communities; the Federal Reserve Bank of New York; and regulators, legislators, international organizations and Financial Intelligence Units in Europe, Latin America, Canada, Asia Pacific, and the Middle East and North Africa.
Mr. Koch represented Western Union on FinCEN’s Bank Secrecy Act Advisory Group (“BSAAG”), which was created by the U.S. Congress to advise the Secretary of the Treasury on Bank Secrecy Act issues. He was a member of the Supervisory Board of Western Union International Bank GmbH, and is Chairman of the Advisory Board of the Association of Certified Financial Crime Specialists. He has been an active participant in industry groups such as The Wolfsberg Forum, the New York Clearing House and American Bankers Association AML Committees, and the United States Treasury Department’s AML Private Sector Dialogue.
Mr. Koch served as Chairman of the New York State Bar Association’s Committee on the United Nations, as Chairman of The Consular Law Society, Inc., as Legal Counsel to The Society of Foreign Consuls in New York and as Co-Chairman of the New York Chapter of the Association of Certified Anti-Money Laundering Specialists (“ACAMS”). He also taught courses in International Business Law as an adjunct faculty member of Fordham University’s Graduate School of Business Administration.
At the 2014 conference Not for Sale—Joining Forces Against Trafficking in Human Beings, convened by the Council of Europe and the OSCE, Mr. Koch delivered a presentation on Customer and Financial Transaction Traits that May Present Risk for Human Trafficking. This was a follow-up to his earlier presentation to a plenary session of the United Nations Office on Drugs and Crime/OSCE’s Expert Seminar on Leveraging Anti-Money Laundering Regimes to Combat Human Trafficking. A founding member of the U.S. and EU Bankers’ Alliances Against Human Trafficking, he has delivered numerous presentations on the topic. (see sidebar)
Mr. Koch received his Juris Doctor degree from the New York University School of Law, and his Bachelor of Arts degree magna cum laude from the University at Albany. He has studied in Copenhagen, Cambridge and Warsaw. He wrote the screenplay for "Money Laundering: A Global Menace", the anti-money laundering training video used widely in the financial services industry.
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
New York University School of Law, Juris Doctor
University at Albany, SUNY, Bachelor of Arts – magna cum laude
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
Combatting 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’ Conference 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
Breaking the Financial Chains: Disrupting Financial Flows Associated with Slavery, Human Trafficking, Forced Labour and Child Labour, United Nations University
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