Mary M.F.

Rand, AMLP, CIA, CFSA, CBM

North Syracuse, NY 13212 315-391-1075 mmrand@verizon.net

Compliance Officer / Auditor - Expertise in AML / BSA program compliance and internal controls / regulation auditing. Committed and dedicated to quality service, observant, organized, self-motivated, and persistent and resourceful to meet challenges and scheduled deadlines despite obstacles. Comfortable communicating with all levels of management and Regulators orally and in writing. Known as an individual contributor but also able to thrive in a diverse team environment. PROFESSIONAL EXPERIENCE Assistant Vice President, Anti-Money Laundering Director - AML / OFAC Compliance AXA Equitable (formerly The MONY Group), Syracuse, NY 2006-2011 2002-2006

Administered Anti-Money Laundering (AML), Bank Secrecy Act (BSA), Office of Foreign Assets Control (OFAC) and USA PATRIOT Act compliance for 16 business units and 2 subsidiaries since inception. Investigated transactions to identify suspicious activity. Generated the Corporate AML and OFAC Compliance Manuals and corresponding risk assessments. Represented AML Office in numerous corporate initiatives. Effectively administered the compliance program from a remote location Responded to IRS 8300 penalty notification letters. Mitigated the penalty 100% of the time Interpreted laws and regulations to correspond with Internal Audit and Regulator expectations with a satisfactory or above audit rating 95% of the time Trained over 2,000 employees on AML and customized sessions to the internal external audience Identified areas to comply with the Customer Identification Program (CIP), determined the process, developed procedures and trained users before the mandatory compliance date Created an enhanced due diligence process (EDD) for CIP issues resulting in 100% regulatory compliance Implemented the OFAC scanning process throughout MONY and AXA, including vendor selection, software testing, procedure generation, personnel training, and auditing results Converted the CIP and OFAC processes to Bridger XG; tested the software to determine the changes; decided risk rating parameters; created various procedures; audited the conversion process for accuracy and trained approximately 400 users within the accelerated six month deadline Senior Auditor 2000-2002 The MONY Group, Syracuse, NY Completed risk assessments and developed internal control programs specific to the audit. Discussed audit findings with respective management throughout the course of the audit to generate a complete and accurate report. Completed special projects to detect and deter possible fraud. Investigated the legitimacy of a fraud case. Saved the company over $50,000 Researched cases of suspicious activity as identified by home-grown adhoc reporting. Brought an nine-month backlog up to date in three months Partnered with internal customers during corporate initiatives to ensure adequate design of internal controls Identified up to three efficiencies during each departmental audit under my responsibility Assisted senior management in audit plan creation and adherence due to personnel changes. Plan met 100% of the time

Mary M.F. Rand

mmrand@verizon.net / 315-391-1075

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Compliance Auditor 1994-2000 Community Bank, N.A., Syracuse, NY Created and updated existing audit programs to include all applicable procedures, controls, Uniform Commercial Code (UCC) Laws and Code of Federal Regulations (CFR) Regulations affecting a National Bank. Supervised and directed staff on financial, department and branch audits which included components of The Bank Secrecy Act, 31 CFR Chapter X. Added regulatory references to relevant program steps so they were readily available for report violations. Positive feedback on this stated in Office of the Comptroller of the Currency report Interacted with all levels of management to enable successful completion of audits and report generation within budget Conducted quarterly training sessions with the audit staff on compliance auditing procedures and current regulatory matters Senior Auditor 1988-1994 Fleet Bank, Buffalo, NY Managed multiple audits simultaneously ranging from 100 to 800 budget hours. Completed audits within budget 98% of the time through staff supervision, direction and evaluation PROFICIENCIES Bridger Systems MS Word Corporate Risk Assessments Problem Solving Due Diligence DESIGNATIONS Anti-Money Laundering Professional (AMLP) Certified Financial Services Auditor (CFSA) EDUCATION / PROFESSIONAL DEVELOPMENT BS Accounting, 1988; State University of New York, Oswego College, Oswego, NY (Minor in Economics and Mathematics with a Statistics Concentration) Maintain an active status on all designations and stay abreast of regulatory changes through forums, conferences, local meetings and webinars Deloitte's AML Strategic Leadership Group - Update on ICE Investigations, 9/14/11 Institute of Internal Auditors - How Technology Issues Affect Your IT Rating and Bank Regulators' Views of Your Risk Management Practices, 9/8/11 Crowe Horwath - Doing More with Less: Developing Robust Compliance, 8/24/11 SPEAKING ENGAGEMENTS Professional speaker on various AML and OFAC topics at renowned conferences and forums 2011 American Conference Institute's (ACI) AML & OFAC Compliance for the Insurance Industry - "AML Training: Ensuring that Employees Have the Tools and Knowledge Necessary to Meet the Company's Compliance Obligations" 2010 ACI's National Forum on OFAC Enforcement & Compliance - "Implementing a Robust Screening Program to Detect all Restricted Parties" Certified Internal Auditor (CIA) Certified Business Manager (CBM) LexisNexis MS Excel Report Generation Project Management Policy Analysis World-Check MS PowerPoint Analytical Thinking Results Oriented Outlook / Lotus Notes