Michael Buffardi is a Managing Director in the Financial Services practice of the Forensic & Litigation Consulting segment. He joined FTI Consulting after more than 12 years with the federal government, having worked at both the Financial Crimes Enforcement Network (FinCEN) and Securities and Exchange Commission (SEC). Mr. Buffardi has extensive experience in financial crimes compliance as an attorney-examiner, enforcement investigative attorney, and policymaker. He has presented on regulatory compliance “best practices,” taught seminars on effective techniques for examining financial institutions, and his enforcement investigations resulted in some of the highest AML civil money penalties imposed by the SEC.
Mr. Buffardi has extensive experience with Bank Secrecy Act (BSA) and anti-money laundering (AML) compliance, securities regulation, and complex investigations. He has worked on matters ranging from transaction “look-backs” for banks, to sales practice and supervisory program reviews for broker-dealers, and AML program remediation and enhancements for money services businesses (MSB).
Mr. Buffardi served as a senior attorney in both the SEC’s Division of Enforcement and Division of Examination. In these roles, he worked on complex investigations and examinations of SEC-registered entities, including broker-dealers, registered investment advisers, and municipal advisors. Mr. Buffardi’s investigations and examinations involved areas such as AML and Office of Foreign Assets Control (OFAC) sanctions, supervisory controls, microcap/penny stock trading analysis, pump-and-dump schemes, and insider trading.
While at FinCEN, Mr. Buffardi had a broad array of responsibilities, having served as both a special advisor in the Regulatory Policy and Programs Division and as the bureau’s liaison between two Undersecretaries of Terrorism and Financial Intelligence and two FinCEN Directors. He was also the bureau’s liaison to the Law Enforcement and Non-Bank Financial Institutions Subcommittees of the Bank Secrecy Act Advisory Group (BSAAG). Mr. Buffardi drafted several FinCEN advisories on emerging threats to financial institutions, multiple BSA regulations, and BSA/AML interpretive guidance. He also assisted a variety of financial institutions, including depository institutions, MSBs, casinos and card clubs, and securities/futures firms, with BSA/AML compliance and regulatory interpretations.
Mr. Buffardi has conducted trainings and given presentations on using BSA data in white-collar criminal investigations, best practices for BSA/AML examinations of broker-dealers, and BSA/AML compliance obligations and best practices for both bank and non-bank financial institutions.
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Regulation and Compliance
Sanctions Investigations & Compliance