Timothy Dunfey

Timothy Dunfey

Timothy Dunfey, CFE, CAMS, is a Bates Group Expert with 16 years of experience in financial services operations and compliance. Mr. Dunfey is a highly-seasoned professional experienced in all facets of AML and OFAC processes, regulatory communications, corporate governance, investigations and risk management.

Mr. Dunfey has assisted financial institutions and their Boards to address regulatory criticism and manage AML and OFAC risk during times of significant regulatory pressure and public scrutiny. He has experience hiring, managing and developing staff as well as executing AML/OFAC engagements, risk assessments and systems implementations in the U.S. and Canada.

His expertise managing and directing engagements is spread over the following specialties: 

· Regulatory and Board Communication Management

· AML and OFAC Policies & Procedures 

· AML and OFAC Risk Assessments

· AML and OFAC Systems Selection and Implementation/Tuning  

· Independent AML And OFAC Systems Validations

· Highly Confidential AML and Fraud Investigations

· Quality Assurance and Testing 

· Project Management 

· Internal Audit 

· AML/OFAC Training   

· Problem Solving 

· Presentation & Communication Skills 

· International Experience

After receiving his J.D., being admitted to the bar and legal practice, Mr. Dunfey held the role of Deputy BSA Officer at Great Florida Bank where assisted in the implementation of the automated monitoring system, managed complex investigations and filed SARs.  Subsequently he held the role of Compliance Officer in Citibank’s compliance department and manager of a team of 50 KYC professionals across five lines of business (Brokerage, Private Banking, Retail Banking, International Personal Banking and Global Transaction Banking). 

As a consultant, Mr. Dunfey has worked with teams to represent the board of directors of some of the world’s largest financial institutions to better understand their responsibilities and improve compliance processes while under a regulatory Order to comply.  More recently, Mr. Dunfey has worked with institutions small and large regarding BSA/AML and OFAC Audits, Risk Assessments, Regulatory Risk Inventories and Risk Assessments, customer and product risk ratings, third party validations of monitoring programs, policies, procedures and process improvements. 


Timothy Dunfey

A Consultant and subject matter expert in these services:



Alhambra Compliance, President, April 2011 - Present

Promontory Financial Group, Consultant, , March 2011 – July 2013; March 2014 – February 2015

Citibank N.A., Compliance Officer, April 2010 – April 2011

Alhambra Compliance Consultants, Independent Consultant, October 2007 – April 2010

Great Florida Bank, Deputy BSA Office, January 2007 – October 2007

Morgan Stanley, Wealth Manager and Registered Investment Advisor, 2000 – 2003

American Express, Registered Investment Advisor, 1999 – 2000

First Union National Bank, Teller, 1994 – 1996


The University of Florida, Gainesville, FL, B.A., Criminology and History, 1994 – 1998

St. Thomas University School of Law, Miami Gardens, FL, J.D., with Honors, 2003 – 2006


Florida Bar 

Federal Courts, Southern District of Florida