Amber Vitale specializes in economic sanctions, anti-money laundering (AML) and anti-bribery/corruption compliance. Her expertise includes conducting OFAC investigations; financial crimes-related regulation and compliance; and risk management and internal controls. Amber is experienced at identifying complex regulatory issues, assessing compliance programs, and developing and implementing tailored compliance solutions for her clients.
Amber has 16 years of experience working on OFAC investigations and compliance matters involving numerous industries, including financial services, oil and gas, shipping, heavy equipment, agriculture, and real estate, among others. Amber has been a sanctions expert and liaison to investigators and prosecutors from federal, state and local agencies, such as the U.S. Department of Commerce, Department of Justice, and Manhattan District Attorney’s Office.
Prior to joining FTI Consulting, Amber worked at OFAC for five years, including three years as a Section Chief in Enforcement, and held positions as an in-house compliance officer, as well as an external consultant and legal advisor. Most recently, Amber was the Head of Sanctions Advisory at Brown Brothers Harriman & Co. (BBH) where she was responsible for sanctions investigations, disclosures and reports; sanctions compliance guidance; and sanctions training. At BBH, Amber developed enhanced processes and procedures, and performed analyses (e.g., of lists and filter settings used for sanctions screening) for DFS Part 504 requirements. As a Senior Compliance Officer for Economic Sanctions and Assistant General Counsel at AIG International, Amber revised the global policies for AML, sanctions, export controls, anti-boycott, and anti-bribery and corruption in addition to conducting sanctions investigations and drafting regulatory submissions.
In previous roles as a consultant to financial institutions, including as a Director in PwC’s Financial Crimes Unit, Amber provided subject matter advice and led delivery teams focused on AML and OFAC-related projects. Amber was also an Associate at Schulte Roth & Zabel LLP in New York, where she provided legal counsel to financial institutions, including banks, broker dealers, insurance companies, and money-service businesses, as well as investment advisors, fund managers and other global companies.
Amber received a Bachelor of Science in Communications from Ithaca College, and a Juris Doctor from Georgetown University Law Center. She is admitted to the New York bar and is a member of the Association of Certified Anti-Money Laundering Specialists (ACAMS). She is also a member of the Association of Certified Sanctions Specialists (ACSS) and is on ACSS’s Government Relations Task Force.
- Assessing the global sanctions program of a financial services firm (one of the world’s largest asset managers and custodians) and developing a Target Operating Model;
- Performing an enterprise-wide assessment of the sanctions screening controls in place for the transaction data of a global investment firm, including documenting screening processes, recommending other risk-mitigating controls, and identifying gaps in the data sent sanctions, PEP and negative news screening;
- Advising the New York branch of a non-U.S.-based global financial institution (world’s largest multinational bank measured by assets) during the transition to FircoSoft, including drafting Business Requirements Document and Tuning and Testing Reports, and creating test data and cases for User Acceptance and Functional Testing;
- Analyzing the sanctions lists and FircoSoft algorithm and severity mode settings of a global custodian bank (largest private bank in the U.S.) in preparation for NYSDFS Part 504 requirements; and
- Conducting OFAC investigations and drafting OFAC disclosures involving (1) securities-trade-related messaging services provided by a major U.S. company, (2) agricultural goods sold to Cuba by a U.S. company’s Canadian subsidiary and related back-office services provided in the U.S., and (3) sales of nutritional products to Iran by a non-U.S. company that was acquired by a U.S. company.
T: +1 646 453 1269
M: +1 646 512 2859
Three Times Square
New York, NY, 10036
Regulation and Compliance
Risk Management & Internal Controls
Sanctions Investigations & Compliance