Michael T. Zarzecki

Senior Director

New York

Michael T. Zarzecki is a senior director with K2 Integrity’s Financial Crimes Compliance practice. With almost two decades of financial services industry experience, he works with major international financial institutions to review and assess their U.S. Office of Foreign Assets Control (OFAC) and Know Your Customer (KYC) sanctions compliance programs and to guide the implementation of necessary program improvements and enhancements. To ensure that clients’ compliance programs comply with U.S. and international regulations and standards, Mike reviews and assesses their anti-money laundering (AML) oversight and controls and monitors changes to policies and procedures.

Prior to joining K2 Integrity, Michael worked at Bank of America, most recently as a vice president. During his tenure at Bank of America, he served as a team lead on the specialized investigations team in the bank’s Global Financial Crimes Compliance group, focusing on economic sanctions relationship reviews and consumer banking customer remediation for individuals who are either citizens or residents of sanctioned countries. Michael was responsible for developing and implementing contractor training programs, onboarding and training individuals and various entities, ensuring policies and procedures were compliant with regulations, and leading QA/QC testing reviews, specifically as the point person of a consumer bank customer remediation project ensuring proper U.S. government–issued identification for a group of more than 30,000 citizens and/or residents of sanctioned countries.

Michael previously worked for Bank of America Specialist, a former division of Bank of America, as a trader’s assistant on the floor of the New York Stock Exchange, where he was responsible for recording and executing every trade for his assigned panel of stocks.

Michael received a B.A. in economics and finance from Bucknell University. He is FINRA Series 7 registered.

Representative Matters

For a large multinational bank facing regulatory scrutiny, Mike and his team worked to, among other things, review and revamp the bank’s sanctions compliance program. They assessed the client’s KYC and OFAC sanctions escalating and reporting, list management updates, and static data screening. Mike served as a workstream lead for KYC and sanctions escalating and reporting, conducting interviews and reviewing customer KYC file and OFAC block and reject reports. He also conducted walkthroughs of system tools and case management tools, including Fircosoft. Mike reviewed trade finance letters of credit for the bank’s interests in Singapore, Hong Kong, France, Belgium, and Portugal to ensure compliance with their terms. In addition, he wrote the KYC and sanctions escalating and reporting sections of the project end report.
As part of a regulator-imposed monitorship for a large private bank, Mike and his team conducted onsite reviews of KYC and customer files to determine connections to specially designated nationals (SDNs) or OFAC sanctioned individuals, entities, and countries. He also assisted with transaction review and research on client customer counterparties.
Mike worked as project team lead for the OFAC workstream of a multiyear compliance review of large bank facing a regulator-imposed monitorship. He conducted various interviews and walkthroughs and provided valuable recommendations to improve the comprehensiveness of the bank’s sanctions compliance program. This included onsite and remote testing of transactions and static data screening using Prime OFAC Reporter and Fiserv tools. As project team lead, he liaised with the OFAC office and was responsible for writing the OFAC section of the quarterly progress report.