Michael Buffardi

Michael Buffardi is a Managing Director in the Financial Services practice of the Forensic & Litigation Consulting segment. Mr. Buffardi joined FTI Consulting after more than a decade with the U.S. federal government, having worked at both the U.S. Securities and Exchange Commission (“SEC”) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”). Mr. Buffardi has extensive experience in securities regulation and financial crimes compliance as a policymaker, examiner, enforcement investigative attorney, consultant and expert witness.

Since joining FTI Consulting, Mr. Buffardi has been frequently retained to serve as a regulator-mandated Independent Compliance Consultant (“ICC”) subsequent to state and federal enforcement actions and as an expert witness in complex investigations involving various financial institution types and organizational structures. In his ICC and expert witness capacities, Mr. Buffardi engages often with state and federal regulators on matters that involve banks, cryptocurrency companies, broker-dealers, registered investment advisers (“RIA”), futures commission merchants (“FCM”) and money services businesses (“MSB”).

Mr. Buffardi is also regularly retained by financial institutions proactively, including to conduct Bank Secrecy Act/anti-money laundering (“BSA/AML”) independent compliance program reviews, gap assessments and remediations, and policy and procedure uplifts. He has assisted numerous clients by leading complex internal investigations, large and time-sensitive compliance reviews and transaction “lookbacks”, transaction monitoring program testing and tuning, transaction monitoring coverage assessments and model validations, as well as wholesale compliance program operating model re-designs.

While at the SEC, Mr. Buffardi served as a senior attorney in both the Division of Enforcement and the Division of Examinations, conducting investigations and examinations, resulting in multiple SEC merit awards. He served as a lead field examiner on complex reviews of SEC registrants, including broker-dealers and RIAS, for various types of fraud, compliance and supervisory controls, books and records, and sales practices. The enforcement investigations and examinations that he led, involving BSA/AML compliance, resulted in some of the highest 17a-8 civil money penalties ever imposed by the SEC.

While at FinCEN, Mr. Buffardi had a broad array of responsibilities, having served as both a Special Advisor for non-bank financial institutions (“NBFI”) in the then-Regulatory Policy and Programs Division and as the bureau’s liaison between the Undersecretary of Terrorism and Financial Intelligence and two FinCEN Directors. He was also the FinCEN liaison to the NBFI, Securities and Futures, and Law Enforcement 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 interpretive guidance. As a BSA/AML specialist, he assisted a variety of financial institutions, including securities/futures firms, banks, casinos and MSBs, with compliance concerns and clarifying regulatory interpretations.