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Expert developed an expertise in anti-money laundering (AML) starting in approximately 1995, while he was working as an Assistant Director of the Enforcement and Compliance Division in the Law Department of the Office of the Comptroller of the Currency (OCC). He has continued to work in this area as a consultant and expert witness since he retired from the OCC in 2005. He has written extensively in the AML area; has provided AML training numerous times; and is designated as a Certified Anti-Money Laundering Specialist by the Association of Certified Anti-Money Laundering Specialists (ACAMS). He is also a Board member of the ACAMS D.C. Chapter. Expert, as noted above, has worked extensively in the anti-money laundering (AML) area and with regard to interpreting and enforcing the Bank Secrecy Act (BSA). In addition, he researched and drafted a report for the American Banker's Association recommending five major reforms to the country's BSA/AML regime which was provided to the incoming Obama administration. As part of this effort, he researched and wrote a comprehensive legislative history of the BSA for the report, detaining its legislative and regulatory history from 1968 to 2008. Expert worked for 30 years as an attorney and then an Assistant Director in the Enforcement and Compliance Division of the Office of the Comptroller of the Currency (OCC). In that role, he investigated, presented, negotiated and, when necessary, litigated administrative actions against banks and their officers and directors for potential violations of banking laws and regulations and unsafe and unsound banking practices. Since retiring from the OCC in 2005, he has continued to work in this area as a consultant and an expert witness.