Amber Vitale is a Managing Director in the Financial Services practice for FTI Consulting in New York, specializing in economic sanctions, anti-money laundering (AML) and anti-bribery/corruption compliance. Her expertise includes conducting OFAC investigations; financial crimes-related regulation and compliance; and risk management and internal controls. Amber is experienced at identifying complex regulatory issues, assessing compliance programs, and developing and implementing compliance solutions. She has 15 years of experience conducting investigations and working on compliance matters involving numerous industries, including financial services, oil and gas, shipping, heavy equipment, agriculture, and real estate, among others. Amber has been a sanctions expert and liaison to investigators and prosecutors from federal, state and local agencies, such as the U.S. Department of Commerce, Department of Justice, and Manhattan District Attorney’s Office.
Prior to joining FTI Consulting, Amber held in-house compliance positions, roles as a compliance consultant and legal advisor, and worked at OFAC for five years, including three years as a Section Chief in Enforcement. Most recently, Amber was the Head of Sanctions Advisory at Brown Brothers Harriman & Co. (BBH) where she was responsible for conducting sanctions investigations, drafting disclosures and reports, providing guidance on sanctions compliance, and developing and delivering sanctions training to the firm. At BBH, Amber developed enhanced processes and procedures, and performed analyses (e.g., of lists and filter settings used for sanctions screening) in preparation for DFS Part 504 requirements. She was also a Senior Compliance Officer for Economic Sanctions and Assistant General Counsel at AIG International where she focused on conducting sanctions investigations, drafting regulatory submissions, and revising compliance policies and procedures for AML, sanctions, export controls, anti-boycott, and anti-bribery and corruption.
Previously, Amber spent three years as a consultant to financial institutions, including as a Director in PwC’s Financial Crimes Unit, Risk and Regulatory practice, where she provided subject matter advice and led delivery teams focused on AML and OFAC-related projects.
Representative matters that Amber has worked on include: Developing a recommended Target Operating Model for a U.S.-based global firm providing asset management, custodian, and other financial services to improve governance and oversight, create clear responsibilities and reporting lines between and within the first and second lines of defense, and align the program with leading industry practices and regulatory expectations; Advising the New York branch of a non-U.S., global financial institution on the implementation of a new sanctions screening filter in connection with the Business Requirements Document, Tuning and Testing Reports and test data and test cases for User Acceptance and Functional Performance Testing; and Performing an enterprise-wide assessment of the sanctions screening controls in place for the data of an international U.S. investment firm, including documenting screening processes and other risk-mitigating controls, providing recommendations for additional screening or controls, and identifying gaps in the data sent for sanctions, as well as PEP and negative news screening.
In addition, Amber spent four years as an Associate at Schulte Roth & Zabel LLP in New York, providing legal counsel to financial institutions, including banks, broker dealers, insurance companies, and money-service businesses, as well as hedge funds and other global companies. Amber provided regulatory guidance, often in connection with complex financial transactions, and conducted OFAC investigations, for example, involving the securities-trade-messaging services provided by a major U.S. company, and regarding agricultural goods sold to Cuba by the Canadian subsidiary of a U.S. company. She also drafted disclosures, policies, training documents, and various AML, sanctions and FCPA-related business documents.
Amber received a Bachelor of Science in Communications from Ithaca College, and a Juris Doctor from Georgetown University Law Center. She is admitted to the New York bar and is a member of the Association of Certified Anti-Money Laundering Specialists (ACAMS) and Association of Certified Sanctions Specialists (ACSS).