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Marie Gervacio is a Senior Managing Director with over 20 years of consulting and audit experience in the financial services industry. She is based in Hong Kong and has served clients throughout Asia-Pacific since 2004. Marie primarily focuses on risk & control, governance, fraud, and financial crime, and is a frequent event speaker and panelist at industry body forums and client workshops in Hong Kong and across the region.
Marie’s leadership experience includes:
- Responsible for advising global and local financial institutions on Securities and Futures Commission (SFC) and Hong Kong Monetary Authority (HKMA) requirements and expectations, including, but not limited to: Know Your Customer; Anti-Money Laundering & Counter-Financing of Terrorism; Fraud, Anti-Bribery & Corruption; Culture, Conduct & Investor Protection; Risk Management Frameworks & Internal Controls; SFC & HKMA License Applications & Ongoing Compliance; Internal Audit.
- HK Internal Audit Leader – Responsible for strategic planning and market coverage; projects included but were not limited to: local regulatory compliance for a large European banking group across Southeast Asia, Hong Kong SFC requirements of a large Indian bank, and HKMA and SFC regulatory compliance reviews for several international financial institutions.
- Financial Markets Infrastructure Change Leader – Led several large-scale international banking projects across the region, covering 10+ Asian jurisdictions, to educate and support both buy-and sell-side financial institutions in their understanding and implementation of the effects of the market’s transition away from IBOR rates at the end of 2021, as well as the European Securities and Markets Authority (ESMA) Markets in Financial Instruments Directive (MiFID) II, which introduced widespread, systemic change into the European and international financial markets across operations, financial instruments, and trading venues.
Governance, Three Lines of Defence, Risk & Control
- Advised the C-Suite and “1-down” executives of an international bank on a phased approach to analysing and improving the over-arching risk culture of the organisation, including executive workshops, surveys to gauge risk sentiment, training on “tone at the top” vs. “tone at the middle”, policies and procedures review, and remediation.
- Led an APAC-wide review of a large financial services institution’s Compliance Function, including surveys and interviews of key stakeholders across the organisation, to identify issues and opportunities for improvement on engagement and partnering between first line business teams and second line risk and compliance teams.
- Led the gap analysis and uplift of the Risk and Control Self-Assessment (RCSA) process of an international bank, including review of key risk identification, mapping and classification to control libraries, walkthrough and testing of key controls for design and operating effectiveness, mapping to operational risk classifications and risk appetite definitions, proposing solutions, and supporting implementation of controls uplift.
- Performed a comprehensive review of the Operational Risk Framework for the Financial Controller’s function of a large Swiss-based international banking group, including walkthroughs of end-to-end financial accounting and reporting processes, review and documentation of all risks and related controls (including key risk classifications) across four Asia-Pacific jurisdictions, and mapping to management information reporting.
- Performed internal controls framework review, enhancement, and build, including a significant project at a multilateral development bank based in Beijing, covering large-scale controls uplift of the Office of the Controller: fraud risk assessment and management, policy and framework design and build, ICFR analysis and implementation, target operating model design, loan processing controls uplift, and financial reporting controls uplift
Know Your Customer, Anti-Money Laundering & Counter-Financing of Terrorism
- Led an end-to-end review of the AML/CTF and Sanctions risk management framework at an international corporate bank with large APAC trade finance operations; the review included gapping to HKMA requirements, creation of risk and control libraries, mapping to the operational risk framework, and remediation of findings through solution implementation support
- Led the remediation of several hundred KYC files for a large international bank, including review of completeness and accuracy of file documentation, training and advice to client onboarding and compliance teams, and gapping against KYC and AML/CTF requirements in Hong Kong
- Supported the investigation of traders at an international financial institution for failures to adhere to cross-border trading activity restrictions associated with SFC licensing requirements, including full review of e-mail, telephone, and Bloomberg correspondence
- Led the Asia-Pacific review of a large Australian bank’s AML/CTF and Sanctions framework to create an internal business case for enhancement of their framework controls and technology to obtain head office funding
- Led the review of an SFC-licensed Southeast Asian brokerage and asset manager in Hong Kong, including an end-to-end review of compliance with SFC AML/CTF and KYC requirements and expectations, and related remediation implementation to address observations and findings