Goldman Sachs · Tradeweb · 30 Years

Built the Systems.
Transformed the Organization.
Audited the Controls.

Independent Technology Audit & Controls Consultant for TradFi institutions and for stablecoin participants navigating a July 2026 implementation deadline. The OCC, FDIC, and FinCEN are still finalizing the NPRs that define what a compliant stablecoin control environment looks like across the ecosystem. What this moment requires is not more legal analysis — it is someone who can translate regulation → blockchain control architecture → auditability.

See the Stablecoin Compliance Hub →

TradFi Institutions
ITGC · SOX 404 · ERM · Operational Resilience
Trading & Post-Trade · FFIEC · Third-Party Risk · Pre-IPO SOX
Stablecoin & Digital Asset
PPSI Controls · 11-Layer Control Stack · Reserve Attestation · OCC Exam Prep · FinCEN AML/CFT
// Career at a Glance
30+
Years in financial technology, risk, and audit
9+
Years at Goldman Sachs — GBM trading and post-trade, global offices
3
Career phases: Trading Systems Developer · Transformation PM · Auditor
On-site or remote · Embedded or independent
// Institutional Experience
Goldman Sachs Tradeweb JPMorgan Bank of America Bear Stearns
// Consulting & Project Experience
UBS Credit Suisse HSBC Citigroup Bunge
// Core Audit & Risk Capabilities
IIA / QAIP COSO / ERM / ORM SOC / SOX 404 NIST CSF / FFIEC IT Handbook ITGC / ITAC Cybersecurity Operational Resilience BCP · DR Trading Systems

My Background

Three distinct roles over thirty years — building financial systems, leading technology transformation across global institutions, and conducting technology audits. Each phase built directly on the one before it.

// 1997 to 2005
Trading Systems Developer
Bear Stearns · JPMorgan · Bank of America · Bunge
Built front-office trading systems for Commodities, Repo, Swaps, and Equity Derivatives — trade capture, clearing and settlement, MTM valuation, and risk management. Led Bank of America Tokyo's equity platform in collaboration with the Japanese regulator. That systems background informs how I approach technology audits — understanding the design and architecture before assessing the controls.
// 2006 to 2015
Technology Transformation Program Manager
UBS · Credit Suisse · HSBC · Citigroup · Bunge
Led technology transformation programs at global financial institutions — HSBC Mexico KYC/AML migration, Citigroup Canada futures platform integration, trading and operating model redesign at UBS and Credit Suisse. Translating regulatory requirements into executable technology change across multiple jurisdictions is the delivery backbone I bring to every engagement.
// 2015 to 2025
Technology Auditor and Risk Manager
Goldman Sachs (Global Banking & Markets) · Tradeweb Markets
Nine years at Goldman Sachs auditing trading, post-trade, and risk platforms across New York, Hong Kong, and Salt Lake City — ITGC, SOX 404, ERM, cybersecurity, and operational resilience. Built the GS Salt Lake audit function and supported GS China's regulatory readiness for CSRC licence approval, assessing that trading and post-trade control frameworks met CSRC requirements for market entry. At Tradeweb: SOC, SOX, BCP/DR, AWS cloud, and cybersecurity for electronic trading platforms.

That progression is the credential. A practitioner who built trading systems at Bear Stearns and JPMorgan, led regulatory technology programmes across six global institutions, then spent nine years auditing those same system types at Goldman Sachs sees control gaps differently. Most failures trace back to a change management weakness, an entitlement blind spot, or a monitoring gap left unaddressed when the operating model was designed — on a core banking system or a blockchain.

Two Domains. The Same Institutional Standard.

Institutional-grade audit methodology applied to TradFi institutions and digital asset firms. The controls are the same. The regulatory overlay and technology stack differ.

TradFi Institutions
Banks, Broker-Dealers, Trading Platforms, and FinTechs

Senior independent execution — audit delivery, regulatory remediation, ERM uplift, or a programme behind schedule. Institutional-grade methodology. Completed workpapers. Fixed deadlines met.

  • ITGC and ITAC audit execution — access, change, IT operations, and application controls with completed workpapers
  • SOX 404 and SOC 1/2 control testing, embedded or independent
  • ERM framework design — COSO-based, with IT Risk Management as an integrated subdomain
  • Operational resilience programme — BCP, DR, crisis management, FFIEC and COSO ERM aligned
  • Trading and post-trade platform audit — front-office controls, clearing, collateral, and regulatory reporting (SEC, CFTC, FINRA, MiFID II)
  • FFIEC examination preparation, regulatory remediation, cloud controls, third-party risk, and pre-IPO SOX build
ITGC · ITAC SOX 404 SOC 1 · SOC 2 COSO ERM FFIEC Operational Resilience Trading Systems Cloud Controls Third-Party Risk
See the Operational Resilience Audit Work Program
Digital Asset and Fintech
Stablecoin Issuers (PPSI), Digital Asset Firms, and OCC Charter Applicants

The GENIUS Act is signed law. The OCC, FDIC, and FinCEN are now issuing concurrent implementation rules — all converging on a July 2026 deadline. Most PPSIs have never built institutional-grade controls inside a regulated framework. That is the gap I have spent 30 years closing at major financial institutions.

  • GENIUS Act reserve certification controls and independent attestation support — three-ledger reconciliation and RPAF coordination
  • OCC PPSI supervision readiness and National Trust Bank Charter ITGC — examination preparation mapped to OCC Cybersecurity Supervision Work Program procedures
  • FinCEN/OFAC and FDIC NPR implementation — AML/CFT program design and prudential control framework build against concurrent agency rulemaking
  • SOC 2 Type II institutional build — control design, evidence standards, and operating effectiveness testing
  • Digital asset custody controls, smart contract change management, and cross-ledger reconciliation architecture
GENIUS Act OCC · PPSI FDIC NPR FinCEN AML/CFT Reserve Attestation SOC 2 Smart Contracts HSM · MPC
See the Stablecoin Compliance Hub
// Stablecoin Compliance · July 2026 Deadline
The Compliance Architecture — From Regulation to Examination

An 11-layer control stack derived from the GENIUS Act, OCC NPR, FDIC NPR, and FinCEN AML/CFT rules — mapped through to OCC examination procedures. Built for stablecoin participants who need to know what a compliant control environment looks like before the examiners arrive.

Stablecoin Compliance Hub ↗ Control Stack →

Three Ways to Engage

If you have a live project, an audit coming up, or a gap on your team, here is how I can step in. I am comfortable working alongside existing teams or independently, on-site or remote, and I focus on delivering completed work rather than recommendations.

01
Embedded on Your Project
You have a GENIUS Act compliance build, a SOX audit, or a regulatory response already underway. I come in, work alongside your team, and deliver completed work. On-site or remote. I pick up where needed and execute to the deadline.
On-site or Remote Audit Execution Controls Build
02
Audit Behind Schedule — Step-In Support
Your audit is behind schedule. Deadlines are fixed. I come in, assess where things stand, pick up the remaining procedures, and complete the work on time. The scope is already defined — I just execute it.
Step-In Execution Fixed Deadlines Audit Completion
03
Retained Independent Oversight
You need senior technology risk and audit expertise available on a continuing basis — for board reporting, audit cycles, regulatory responses, or programme oversight. Monthly engagement, no full-time headcount required.
Board Reporting Audit Cycles Risk Oversight

The Work. Two Domains. One Methodology.

Three methodology artifacts and one case analysis, across two domains. The stablecoin compliance pipeline maps GENIUS Act obligations and concurrent agency NPRs through supervisory examination procedures into an 11-layer control stack built to withstand a federal examination. The operational resilience audit work program applies institutional methodology to TradFi across eight control domains. The cross-ledger integrity platform applies that same methodology to the blockchain reconciliation problem. The pre-trade position limit case analysis demonstrates what compounding control failures look like in a live production trading system audit.

// Digital Asset · Stablecoin · GENIUS Act · OCC NPR · FDIC NPR · FinCEN
Stablecoin Compliance — Regulation to Examination

No published map connects GENIUS Act statutory obligations through three concurrent agency NPRs to what federal regulators will actually test. An 8-tier pipeline traces from legislation through OCC, FDIC, and Treasury/FinCEN rulemaking, NIST CSF 2.0, FFIEC guidance, and supervisory examination procedures into an 11-layer control stack. Every control traces back to a specific legal obligation and forward to the examination procedure that tests it. For a stablecoin participant who has never been through a federal examination, this maps what the regulators are carrying when they walk in the door.

8-Tier Compliance Pipeline 11-Layer Control Stack 3 Agency NPRs GENIUS Act Traceability OCC CSW Mapped 6 Working Documents
11
Control Layers
8
Tier Pipeline
6
Working Documents
// TradFi and Digital Asset · Operational Resilience · ERM
Operational Resilience Audit Work Program

A structured audit work program covering eight core domains — governance, business continuity, disaster recovery, third-party resilience, crisis management, technology resilience, data integrity, and a supplemental digital asset domain. Built for TradFi institutions and digital asset firms. FFIEC, COSO ERM, NIST CSF, and OCC standards mapped throughout. Representative of the work product a senior institutional practitioner delivers on an engagement.

8 Core Audit Domains TradFi and Digital Asset FFIEC Mapped COSO ERM Risk Scoring Test Procedures
8
Audit Domains
2
Audiences: TradFi and Digital Asset
4
Frameworks: FFIEC · COSO · NIST · OCC
// DeFi & Digital Asset · Cross-Ledger Integrity · Reserve Integrity
Cross-Ledger Integrity & Reconciliation Platform

Any environment where a traditional system of record must stay synchronised with a blockchain ledger creates the same structural control problem — two sources of truth must behave as one. This platform documents the reconciliation monitoring engine, a platform architecture comparison across Legacy and Blockchain systems, and a 30-control audit work program across seven domains. The Reserve Integrity Monitor shows what the output looks like running against live stablecoin reserve data. Anchored in GENIUS Act requirements; the control pattern is reusable across industries.

Stablecoin Reserve Integrity Three-Ledger Reconciliation 4 Industry Use Cases Legacy vs Blockchain Architecture 30 Controls · 7 Domains GENIUS Act · OCC · FFIEC · COSO Reserve Integrity Monitor
7
Control Domains
30
Controls Tested
4
Industries Covered
// TradFi · Pre-Trade Risk Controls · CFTC Part 150
Pre-Trade Position Limit Controls — Audit Case Analysis

A TradFi audit case tracing four compounding control failures in a pre-trade Position Limit Monitoring (PLM) system — from a superseded CFTC regulatory standard never updated in code, to OTC positions excluded from the aggregate, to a third-party vendor delta price error accepted without validation. Each gap individually is a finding. In sequence they create a regulatory compliance exposure that appears controlled on the surface. This is the pattern technology auditors find in production trading system audits.

CFTC 17 CFR Part 150 Four-Stage Failure Chain ITGC · SOX 404 Completeness · Accuracy · Timeliness CME Group Exchange Rules
4
Compounding Gaps
3
Audit Assertions
5
Control Objectives

Could It Happen Here?

The same control failures that surface in post-incident regulatory reviews — missing segregation of duties, absent pre-trade gates, no reconciliation — appear in both TradFi and digital asset operations. An auditor's ability to analyse a live incident, map the failure chain to ITGC and ITAC controls, and then ask "does this gap exist in our environment?" is the standard both the OCC and internal audit committees expect. The three panels below show the preventive layer, the failure analysis, and the execution tool — in sequence.

Audit Universe Risk Taxonomy Risk Assessment ← Panel 1 Incident Analysis ← Panel 2 Planning Execution ← Panel 3 Reporting
// Panel 1 · Before It Happens
Stablecoin Control Framework
Eleven control layers mapped to OCC, FDIC, and FinCEN concurrent NPRs — derived from the GENIUS Act and OCC 12 CFR Part 15. Covers governance through real-time monitoring. Designed to survive an examiner's scrutiny, not just an internal checklist.
Stage 1 · Control Design
Stablecoin Control Foundation Guide
Six control areas — what to build, in what order, and what evidence regulators and examiners require across OCC, FDIC, Treasury, and GENIUS Act obligations.
View Guide →
Stage 2 · Risk and Gap Assessment
Stablecoin Unified Checklist
43 items derived from the PRC — one per process step. Every item traces to a specific regulatory provision across OCC, FDIC, Treasury, and GENIUS Act requirements.
View Checklist →
View Full Stablecoin Compliance Hub →
// Panel 2 · When Controls Fail
Incident Analysis
Structured post-incident analysis mapped to ITGC, ITAC, and NIST CSF controls — following OCC Bulletin 2023-17 and FFIEC supervisory expectations. Each analysis identifies the failure chain and asks: does this gap exist here?
DeFi · Stablecoin $25M extracted
Resolv USR Exploit
Unauthorized minting · Single-key compromise · No mint gate · $1.00 → $0.27 peg collapse
Read Analysis →
DeFi · Solana · Governance $285M extracted
Drift Protocol Exploit
Social engineering · Durable nonce multisig bypass · Governance takeover · April 1, 2026
Read Analysis →
View All Case Analyses →
// Panel 3 · How to Test
Stablecoin Technology Audit Work Program
Seven audit domains built from the Risk Taxonomy — test procedures derived from the PRC's 43 key controls. Structured for direct auditor execution. Each domain has a control objective, key risk, test procedures, evidence requirements, and regulatory citations across OCC, FDIC, Treasury, GENIUS Act, NIST CSF, and FFIEC guidance.
D1 · ITGC Access Mgmt
D2 · Change & Smart Contract
D3 · Reserve Integrity
D4 · Cybersecurity & Keys
D5 · AML / BSA
D6 · Third-Party & Custodian
D7 · Governance & Attestation
View Audit Work Program →
Stage 3 of the methodology. Every test procedure tests a PRC key control. Structured for auditor execution — not client self-assessment.

Start with a Conversation.

If you are working through a regulatory examination, a controls gap, an audit that is running behind, or a deadline that is closing in — a short conversation is the right first step. Describe your situation in the form and I will respond personally.

  • No pitch — just an honest discussion about your situation and whether my background is a match for what you need
  • I respond personally, not through an assistant or account manager
  • If I can help I will say so directly. If I am not the right fit for what you need, I will tell you that too.

I work across embedded audit execution, step-in project support, and retained advisory. All engagements start with a scoping conversation at no charge.

Tell Me What You Are Up Against

Responses within 24 hours · All engagements begin with a scoping conversation