Jerome Wells is a senior director in the Financial Crimes Risk Management practice at K2 Integrity. With over 15 years of experience in the financial services industry, he assists multinational financial institution clients with AML transaction monitoring (TM) and sanctions screening reviews, suspicious activity reporting (SAR), regulatory mandated independent monitorships, compliance program model validations, and independent testing. Jerome specializes in AML TM model-related client engagements, including model validations, which involve reviewing model design, data quality and lineage testing, and model governance. He conducts TM scenario threshold testing and tuning, reviewing key performance indicators (KPI) to assess rule productivity, performing statistical transaction analysis, and conducting above-the-line (ATL) and below-the-line (BTL) testing. Jerome also oversees user acceptance testing (UAT) to determine necessary enhancements. His expertise extends to TM system implementation, including rule selection, threshold setting, and parallel and UAT testing, as well as creating risk-based coverage assessments, rule development, and TM BAU and lookback alert reviews.
Prior to joining K2 Integrity, Jerome served as senior vice president and head of KYC onboarding at Lloyds Bank Corporate Markets, managing a team of professionals responsible for the end-to-end customer identification program (CIP) and KYC reviews for new-to-bank customer approvals, as well as the ongoing maintenance of existing customers in compliance with U.S. regulatory requirements and UK regulatory requirements as outlined by the Financial Conduct Authority (FCA). Before that, he was vice president within the bank’s compliance division, where he managed the AML advisory team responsible for the review and approval of all high/very-high-risk customers, ensuring AML policies and procedures were compliant with regulations, performing quality assurance (QA)/quality control (QC) testing reviews, and conducting training.
Before joining Lloyds Bank, Jerome was an associate at Nomura Securities, where he conducted enhanced due diligence reviews on customers onboarded to the U.S. and UK Nomura entities. Jerome also served as a team lead at Morgan Stanley Smith Barney, managing the compliance team covering Private Wealth Management customers, responsible for high-risk EDD, transaction monitoring reviews, and SAR processing and reporting, with a focus on Latin American customers. He previously worked as an intelligence analyst with the New York/New Jersey High Intensity Financial Crimes Area (HIFCA). While at the HIFCA, he was deployed to the El Dorado Money Laundering Task Force, providing analytical support to criminal investigations in the NY/NJ metro area. Additionally, he previously served as an investigator with the Civilian Complaint Review Board (CCRB) responsible for conducting civilian-led investigations regarding complaints against members of the New York Police Department.
Jerome holds a B.S. in criminal justice from St. John’s University.