Koby Bambilia is head of the Financial Crimes Compliance practice at K2 Integrity, based in New York. With more than 20 years of global experience with complex Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) compliance, sanction programs, and regulatory enforcement action matters, Koby helps financial institutions meet the challenges of complying with BSA regulations, the Office of Foreign Assets Control (OFAC), and the USA PATRIOT Act, and assists those facing regulatory enforcement actions. He helps financial institutions adhere to regulatory consent orders that mandate review and enhancement of their AML compliance, BSA, OFAC, and sanctions policies and procedures; implement remedial actions; and comply with consent orders that mandate transaction monitoring lookbacks. Koby assesses institutions’ BSA/AML and sanctions compliance programs, including Know Your Customer (KYC), customer due diligence (CDD)/enhanced due diligence (EDD), customer risk rating and customer identification program (CIP) regulations; mandatory BSA reporting; sanctions programs; and transaction monitoring, and helps design programs to increase compliance.
Prior to joining K2 Integrity, Koby was a senior vice president at Leumi Group, a banking group with managed assets of more than $125 billion and global subsidiaries. As the group’s deputy chief compliance officer, Koby led the group compliance corporate governance, overseeing the development and deployment of policies and procedures, including internal controls and quality assurance programs, compliance-related training, and information technology systems. Among other responsibilities, Koby managed the overall implementation of the bank’s policies and procedures in compliance with the U.S. Foreign Account Tax Compliance Act (FATCA), the Organisation for Economic Co-operation and Development’s (OECD) Common Reporting Standard (CRS), and local regulations concerning the risk management of cross-border activities and risk management in view of determining tax offenses as predicate offences. Koby also served as a senior member of the bank’s FATCA, CRS, and cross-border committees.
In addition, he worked closely with a New York Department of Financial Services (DFS) monitor, leading and directing the implementation of DFS recommendations, as well as those related to an enforcement action issued by the U.S. Department of Justice. Among other responsibilities, he managed the bank’s AML investigation department, its transaction monitoring units, its compliance-correspondent banking unit, its onboarding KYC/EDD and periodic review processes, and its suspicious activity reporting (SAR) methodology. He also led account remediation projects as well as historical (lookback) transaction reviews, and directed the bankwide compliance training program. Koby additionally served as a board member of a trust company providing wealth management services to high-net-worth individuals and family offices.
In a prior position as a U.S.-based bank BSA and OFAC officer, Koby managed the bank’s BSA, AML, counterterrorist financing (CTF) and sanctions programs, and directed the bank’s correspondence during regulatory examinations. Koby also led the team responsible for the implementation and validation of a new transaction monitoring system.
Before his time with the Leumi Group, Koby served as a criminal prosecutor conducting complex international investigations, indictments, and forfeiture cases, mainly related to AML, CTF, and fiscal matters. He also served as a lecturer at Tel Aviv University’s Faculty of Law and its School of Business Management.
Koby received an LL.M., magna cum laude, and an LL.B. from Tel Aviv University Faculty of Law. He is admitted to practice law after receiving his license, summa cum laude. Koby holds the military rank of Major (Ret.).