Hugues Penaud

• Manage client outreach and KYC documentation collection in accordance with global regulatory standards
• Act as primary liaison between clients, bankers, operations, and risk teams, ensuring effective communication
• Monitor KYC compliance risks and impact on business operations, addressing policy gaps
• Support periodic KYC refreshes, remediation efforts, and adherence to governance structures

• Led and managed a compliance team of over 30 analysts across 7 third-party entities (BNY, JPM, BNP, APEX, and others), ensuring adherence to CSSF and EU AML directives
• Oversaw onboarding and periodic KYC/CDD refresh processes for institutional investors in Luxembourg, Ireland, and Jersey
• Directed compliance audits, risk assessments, and governance enhancements, improving operational efficiency and reducing regulatory risks
• Implemented a compliance oversight framework, standardizing KYC/CDD procedures and strengthening due diligence practices
• Developed AML training and policy awareness programs, enhancing compliance culture across multiple jurisdictions
• Managed relationships with external regulators, auditors, and legal teams, ensuring seamless regulatory adherence

Clients:

Coinbase, Deloitte, Ebury Belgium, Boku, PPS, Ghana International Bank

Key Contributions:

• Crypto & Digital Asset Financial Crime Compliance: Tailored AML/CTF, CDD/EDD, and risk assessment frameworks for crypto asset service providers (CASPs) and Web3 platforms, ensuring alignment with evolving regulatory expectations.
• Financial Crime Compliance Frameworks: Designed and implemented AML, KYC, transaction monitoring, and financial crime risk assessment policies across traditional banking, fintech, and digital asset institutions.
• Blockchain & On-Chain Transaction Monitoring: Enhanced transaction monitoring (utilizing tools like Lexis Nexis/ World-Check) and fraud prevention controls to detect high-risk patterns, typologies, and sanctions risks unique to crypto and cross-border payments.
• Regulatory Compliance & Governance: Led financial crime risk assessments and policy governance structures, ensuring adherence to FCA, CSSF, ACPR, NBB, FSMA, and EU AML Directives (AML directives 4–6).
• Post-S166 & Compliance Remediation: Conducted large-scale post-S166 reviews and remediation programs, identifying compliance gaps in onboarding and monitoring to reinforce risk management and governance.
• Senior Management & Interim MLRO Advisory: Provided strategic guidance to executive teams and board members on emerging financial crime risks, crypto regulatory shifts, and regulatory liaison.

• Managed the KYC compliance process for investment and guarantee funds, ensuring adherence to CSSF and EU AML Directives
• Conducted integrity checks on high-risk financial structures, including banks, trusts, and fund managers
• Performed in-depth AML risk analysis, identifying areas for process improvement
• Supported internal audits and risk assessments, strengthening compliance frameworks
• Luxembourg

• Managed SME onboarding and KYC/CDD processes, ensuring compliance with UK and EU regulatory standards
• Drafted and revised KYB/KYC policies for Belgium and France operations, ensuring alignment with evolving regulations
• Investigated SARs, sanctions screening results, and financial crime alerts, taking proactive action on flagged activities
• Implemented continuous monitoring strategies, enhancing risk-based compliance controls

• Conducted fraud investigations and transaction monitoring to detect suspicious activities
• Ensured compliance with global gaming regulatory requirements, strengthening internal AML/KYC procedures
• Led training programs for fraud analysts, increasing team efficiency and fraud detection accuracy