John M.
Wagner, III, CAMS
John Wagner has more than 40 years of regulatory, compliance, and risk management experience and serves domestic and international clients, principally focusing on a company’s compliance, risk management and reputational risk when facing AML/Office of Foreign Assets Control (OFAC)/sanctions regulatory or criminal enforcement actions. These services includes C-Suite training, AML/sanction risk assessment development and reviews; AML/sanctions compliance program development and implementation; C-Suite and AML Officer program oversight and monitoring; customer due diligence assessment and enhancement; suspicious activity monitoring and reporting technology and implementation; training program strategies and execution; compliance program remediation; examination strategies and planning; performance reviews; independent testing execution and assessment; forensic investigations; and expert witness testimony. Engagements serve various types of financial institutions including global domestic and foreign depository institutions, global and domestic non-bank financial institutions (fiat and Blockchain Digital Asset related businesses), casinos, and broker dealers.
Prior to joining Deloitte, Mr. Wagner was the Director for Bank Secrecy Act and Anti-Money Laundering (BSA/AML) Compliance Policy at the Office of the Comptroller of the Currency (OCC). After 32 years with the OCC, he was one of their most senior AML officials at the time of his retirement in May 2014. As Director he was responsible for briefing the Comptroller of the Currency and senior management on issues and recommendations related to BSA changes, creation of OCC and interagency industry guidance; supervisory implications to proposed regulatory and international standards, advisor to OCC’s enforcement committee; examiner training; and acting as the primary liaison to FinCEN, Treasury, OFAC, and the other Federal Banking Agencies. Mr. Wagner also led several OCC committees and working groups offering policy and supervisory direction as well as guidance on remedial actions, innovative supervisory risk identification methodologies, and training initiatives.
Prior to being appointed Director, Mr. Wagner had extensive field examination experience, spending almost two decades as an examiner leading and supporting OCC high profile AML/sanctions examinations across the U.S. as well as internationally. During this time, Mr. Wagner led many critical, high profile, and complex BSA/AML/sanctions examinations, at times working directly with law enforcement, which frequently resulted in regulatory enforcement actions including some civil monetary penalties. Mr. Wagner also mentored, developed, and trained OCC and FFIEC examiners in examination techniques and BSA/OFAC requirements/expectations. Mr. Wagner was selected as OCC’s sole representative in the creation of the first (2005) FFIEC BSA/AML Examination Manual and, as Director, was responsible for the periodic updates.
Mr. Wagner was also the primary liaison to foreign government representatives on AML matters. Mr. Wagner advised and was a U.S. representative to international organizations, such as Financial Action Task Force, Basel’s AML Experts Group, and International Monetary Fund. Mr. Wagner also coordinated supervisory activities and enforcement matters with foreign governments. Mr. Wagner was responsible for developing and providing training to bank supervisors worldwide, including overseas in Barbados, Peru, Chile, and the United Arab Emirates.
Mr. Wagner currently serves as a Board member of the U.S. Capital Chapter for the Association of Certified Anti-Money Laundering Specialists (“ACAMS”).