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Hong Kong Team

Mr. Benny To CFA, CPA(US), LLM, MSc

Co-Founder & Managing Director

Mr Benny To, founder of ComplianceDirect, is a seasoned compliance professional with more than 23 years compliance experience in banking industry and securities industry.  His last position was the Head of Compliance for the private wealth management business of a reputable financial institution group.  He also possesses abundant working experience and knowledge in private banking, corporate banking, retail banking, securities & futures brokerage and a financial regulator.  He is also an instructor on compliance areas for some of the reputable professional training institutions in Hong Kong.





  • Charter Holder of Chartered Financial Analyst (CFA)

  • Member of American Institute of Certified Public Accountants (AICPA)


   University of Wisconsin – Madison (USA)

   Bachelor of Business Administration

   Majors: Accounting, Finance and International Business


   City University of Hong Kong

  • Master of Science – Banking

  • LLM – International Business Stream


  ComplianceDirect Consulting Limited (2016 – now)

  Co-Founder and Managing Director

  • Established the compliance consulting company to provide compliance advisory and support services to SFC licensed corporations and banks


  RBC Investment Services (Asia) Limited (Royal Bank of Canada Group) (2012-2016)

  Head of Compliance Wealth Management

  • Responsible for compliance matters for RBC Wealth Management businesses including private banking, stock and futures brokerage, personal and corporate trusts and fund management businesses in Hong Kong and Singapore

  • Managed the compliance team to provide compliance advices, compliance monitoring, trade surveillance, compliance training, liaison with the SFC/HKMA, licensing, manage SFC inspections and regulatory reviews, suspicious transaction reporting, etc.

  • Acted as Money Reporting Laundering Officer (MLRO)

  Coutts and Co Limited (2008-2009 and 2011-2012)

  Director - Compliance

  • Responsible for compliance matters for Coutts’ private banking business in Hong Kong

  • Provided compliance advices, compliance monitoring, compliance training, and acted as the main compliance contact with the HKMA

  BNY Mellon, Hong Kong branch (The Bank of New York Mellon) (2009-2011)

  Head of Compliance and MLRO

  • Responsible for compliance matters for the businesses in Hong Kong branch including, private banking, corporate trusts, alternative investment services, asset servicing, trade finance, global markets (treasury), etc.

  • Managed the compliance teams in Hong Kong and Taiwan to provide compliance advices, compliance monitoring, compliance training, liaison with the HKMA, licensing, AML/CFT, etc.

  Citi Private Bank Hong Kong (2007-2008)

  Senior Vice President - Compliance

  • Responsible for compliance matters for the private banking business in Hong Kong and product compliance for private banking business in Asia

  • Managed the compliance team in Hong Kong to provide compliance advices, compliance training, etc. and liaison with the HKMA

  Citibank (Hong Kong) Limited (2001-2007)

  Senior Vice President – Compliance and Control

  • Responsible for investment compliance matters for the consumer banking business in Hong Kong and Macau

  • Managed the team to provide compliance advices, compliance monitoring, compliance training, corporate governance, etc. and liaison with the HKMA

  Hong Kong Monetary Authority (1997-2000)

  Assistant Manager – Banking Supervision

  • Conducted onsite examinations, offsite reviews and ongoing supervision on local and international banks

  Bank of East Asia Group (1994-1997)

  Assistant Manager – Treasury

  • Executed trades in money market and foreign exchange markets

  • Managed the liquidity position, trading positions and provided general treasury management for the bank

He is also a part-time lecturer at the Hong Kong Institute of Securities and Investment and the Hong Kong Institute of Banking. He is one of the recognised lecturers for the accreditation of professional wealth management courses. He is also a recognised lecturer in Hong Kong. Up to 4,000 frontline employees in the largest Chinese banks provide compliance training.

Rodney Au

Lead Consultant 

Rodney has over 25 years of practical and processing systems experiences and knowledge in Asia regulatory compliance, financial crime compliance (AML, KYC Due diligence, Sanctions and ABC) and operational risk from sizeable international financial institutions into financial technological tools deliverables for speedier business as well as risk management decisions. He had also held a number of key regulatory positions under the Banking Ordinance including Manager pursuant to 72B of the Banking Ordinance. In addition to a bachelor’s degree in law, Rodney also holds master’s degrees in Corporate Governance, Banking and Finance, and International Business Management.


Professional/Industry Recognition and Membership


   Hong Kong Institution of Banks

   Associate AML Professional (AAMLP)




   The Hong Kong Polytechnic University 

   Master of Corporate Governance

   Manchester Metropolitan University, UK

   Bachelor of Law (LLB)


   Finance City University of Hong Kong

   Master of Arts in International Business & Master of Science


   Trent University, Ontario, Canada

   Honours Degree in Administrative and Policy Studies




  HSBC (2015 - 2019)

  Head of Reputational Risk & Customer Selection, Financial Crime Compliance, Asia Pacific 

  • responsible for the Asia Pacific’s policy and system roll-out of Client Selection and Exit Management as part of the remediation work under the Deferred Prosecution Agreement (DPA) with US Department of Justice

  • financial crime compliance and investigation advisory in relation to the effective resolution of cross-border cases involving different lines of business with the key objective to maintain the quality reputational risk of HSBC

  • Provided financial crime risk training and guidance to the front office in the commercial, private banking and retail businesses as well as the investigation teams


  BNP Paribas (2013 - 2015)

  Head of Customer Due Diligence, Hong Kong/Asia Pacific 

  • Responsible for unifying all KYC Due Diligence teams from business functions of BNPP HK and developed Know your customer due diligence system as one of the critical parts of Financial Crime Compliance remediation plan

  • Reformed and institutionalised due diligence teams from various business functions into one team serving all corporate, investment banking and global markets divisions

  • Successfully completed all remediation work by bringing all customers in proper review cycles enhancing overall portfolio risk profiles

  • Regional responsibility for due diligence teams in 13 locations, comprising the provision of operational support, quality control and process standardization

  • Management and/or participation in steering committees and working groups to enhance policy, productivity, quality assurance, due diligence systems


  Coutts Asia (2010 - 2012) 

  Head of Operational Risk, Asia

  • Responsible for regional leadership and senior management of Coutt’s operational risk management objectives and directions for alignment regional strategic growth plans

  • Provided operational risk reviews on products, business plans, transactions and change initiatives

  •  Establish product review group consisting of and business representatives, allowing speedy and safe product roll outs 

  • Locally implemented group policies, internal control environment certification and scenario analysis, including Sarbanes-Oxley 404 


  UBS Hong Kong (2019-2010)

  Director, Compliance, Private Bank

  • Compliance advisory in suitability, product rollout, business strategy

  • Creation and implementation of policies and procedures to enhance compliance of legal and regulatory requirements for the purpose of protecting the reputation of the firm

  • Assistance in the handling of routine regulatory reviews and enquiries


  National Australia Bank Limited (1996-2009)

  • Compliance and Operational Risk: 

    • Established compliance policy and control frameworks in the areas of regulatory change capture, reporting platform for management oversight, project management, and regulatory engagement

    • Developed and conducted compliance training framework sessions for all staff on compliance regulatory and business requirements including regular fit & proper assessments

    • Provision of a comprehensive, business-enabling and prompt compliance advisory service (licensing parameters, current/new business initiatives and practice) and operations units (operational risk), including post-review monitoring

    • Key support to senior management in all licensing matters including application, registration, relevant notifications and filings for regulated activities and Executive Officer/Relevant Individuals under the SFO appointment of Chief Executive/Alternate Chief Executive/Managers under the Banking Ordinance

  • Marketing & Business development. 

    • Customer information MIS and portfolio analysis (pricing and risk concentration) and streamlining of marketing support and business strategic requirements

    • Effective cost management related to marketing expenditures and successfully utilised HK model to support neighbouring centers

    • Established National Australia Bank mortgage business in Hong Kong (awarded the Asian Banking Awards in Product Marketing 1998)


  Western Union Financial Service Inc. (1994 - 1996)

  Regional Development/ Operations Manager

  • Established Western Union’s first agency network in China in 1995

  • Established Western Union international’s money transfers franchise and agency management in Asia Pacific region and helped business development 

Emily Law

Lead Consultant 

Emily is a senior wealth management and financial services professional with more than 20 years of management experience in multi-national and regional environments, in which 10 years are in the (Private) Banking / Finance sector and Consultancy.


She had been in the roles of COO/Senior Consultant for Compliance and Risk consultancy, Director and Head of Business Operational Risk, First Line Business Operations/Assurance Management/Process Control and Governance with extensive management experience in Business Operational Risks, Internal Process and Procedures, Compliance, Operations, Client Servicing, Complaint Management, international and local regulatory requirements, and familiar with different markets’ best practices. 


She possesses proven management experience and professional knowledge in establishing policies and controls for enhancing operations efficiencies, standards, and markets’ requirements for internal controls, governance and clients’ services excellence.


   University of London, England

   Master of Science in Financial Management (MSc) 

   Queensland University of Technology, Australia

   Bachelor of Business in Business Administration and Management (BBus) 


  ComplianceDirect Consulting Limited (Mar 2020 - Dec 2020)

  Chief Operating Officer / Senior Consultant

  • Oversight on the overall management of the consulting business.  Acting as deputy for the CEO / Founder.

  • Provided ongoing professional regulatory (SFC / HKMA) compliance advisory / support services including mock onsite inspections, license applications,  registration, relevant regulatory notifications and filings for regulated activities, compliance / AML and other training.

  • Hands-on consultation on projects including compliance / internal control reviews, remediation engagements, regulatory investigations, compliance & control monitoring programs, complaint handling engagements, and other projects that are Risk related.

  Standard Chartered Bank (HK) Limited (Private Banking) (2017 - 2019)

  Director / Business Operational Risk Manager (BORM)

  • Responsible for leading, managing and implementing the Private Banking Operational Risk Framework and initiatives to ensure operational risks and controls are being managed appropriately to meet external and internal regulatory requirements.

  • Established an effective and adequate risk control environment by designing, revamping existing processes, and implementing control measures and monitoring plans for compliance and operational risk management and to ensure their effectiveness by providing training in relation to Compliance and Operational Risk processes and procedures to all staff.

  • Monitored controls within the Private Banking Business Unit to meet all regulatory and internal requirements. Undertook and / or coordinated periodic business monitoring (Self-Assessment and Gap Analysis) activities and Risk Assessment Controls in coordination with Compliance, BRMs from various locations and across different divisions for governance purposes.

  • Solely responsible in handling all the Private Banking Customer Complaints.

  • Successfully coordinated and participated in various onsite and offsite audits by HKMA and GIA audit reviews and implemented the recommended processes and controls measure within Private Banking business.  

  • Central issues and incidents management and resolution for investigation of potential breaches escalated by the Compliance or Financial Crime Committee (FCC).

  • In charge of Disaster Recovery / Business Continuity for the Private Banking business.

  • Management and / or participation in various committees and working groups to enhance policies, quality assurance, front office systems.

  Barclays Bank PLC (Private Banking) (2014 - 2017)

  Vice President / Business Control and Governance (BCG) / Business Manager

  • Responsible for procedural implementation in terms of continuous enhancement to the Front Office procedures and processes by implementing improvements either as part of the global or local implementation project.

  • Provided supervisory support over the control monitoring processes by leading and coaching regional teams to perform ongoing First Line assurance testing activities, identifying issues and proposing remedial actions.

  • Provided advisory support and resolutions from a Control and Governance perspective to the Front Office in relation to processes, controls, complaint handling, assessing exceptional scenarios and enhancement. 

  • Be the focal point of contact for internal and regulatory audits by coordinating and interacting with the key stakeholders to coordinate and follow up on audit remediation, training and ad-hoc administrative issues.

  • Interfaced with all support areas (Compliance, Fin Crime, Operational Risks, etc.) on issues resolution and organization improvement.

  • Aligned business plan, strategies and priorities, developed framework to facilitate and improve organizational effectiveness and resource efficiency by coordinating resources, providing adequate business analysis and managing projects.

  • Supported Senior Management in planning and implementing specific Front Office projects, leveraged and coordinated best practices and knowledge transfer across the business to optimize business effectiveness and operational efficiencies.

  • Deputized Senior Management and represented the Front Office in regular committee meetings, forums and projects.

  Coutts & Co Ltd.  (Private Banking) (2010 - 2014)

  Vice President / Business Risk Manager

  • Responsible for an adequate and effective management of business risk / assurance responsibilities for the First Line of Defence controls in Hong Kong.

  • Supported senior management to foster a strong culture of risk awareness within Private Banking and to ensure a comprehensive and robust governance framework is in place to support the business in delivering business goals whilst complying with internal and regulatory standards.

  • Ensure the modus operandi of Private banking is up to date and in compliance with applicable laws, regulations, and Group standards.  Coordinated regular reviews and updates for relevant processes and workflow manuals.

  • Acted as the focal point of contact within Private Banking on all audits / regulatory-related issues, projects, inspections and reviews.

  • Designed, managed and supervised regular FLOD testing, Suitability Surveillance program and ongoing monitoring and reporting programs to proactively and efficiently monitor staff compliance. 

  • Led and contributed to major functional / business and risk related policies, processes and procedures initiatives, their implementation, assessment, monitoring, and enhancement to drive through continuous improvement initiatives.

  • Effective management and oversight of business continuity and disaster recovery strategies to ensure the business could provide critical services in the event of a major business disruption.

  SPARX International Hong Kong Limited (Fund of Hedge Funds) (2007 - 2009)

  Associate Director / Investment and Operations Manager

  • Responsible for the management, control and improvement of the entire investment workflow, quality and procedures of the Hong Kong based Fund of Hedge Fund team; monitored productivity; supervised on the compliance to internal procedures and management on various projects.

  • Developed, implemented and monitored quality standards and quality control measures. 

  • Successfully led, managed and coordinated the project in acquiring the accreditation of SAS70 quality assurance qualification within 7 months after joining the team and completed the Control Based Audit soon after. 

  • Participated in operational due diligence on the underlying managers with the research team and all monthly performance and investment meetings. 

  • Analyzed the operational risk incidents / issues with appropriate departments and conducted risk assessment on operational accuracy and consistency. 

  • Managed and led a team of professionals in exploring, investigating and building a new proprietary database for the Fund of Hedge Fund investment and research team.

Prior to 2007, Emily has achieved many accomplishments within the financial industry as a supervisor,  a securities administrator, and an assistant operations manager. As the supervisor of an investment research team in Hong Kong, she built the Hong Kong based multi-Manager Fund of Hedge Funds from scratch to a full team of 8 staff, initiated new methodologies for a smooth transition for the change in management of investment processes,  and provided individual coaching for both investment analysts and investment support staff. Through her other positions, she supervised and controlled the accuracy of back-office settlements, and took appropriate actions to ensure timely settlement on trades when failed transactions are identified.  

Singapore Team

Priscilla Chin

Co-Founder and Managing Director


  • Qualified member – Singapore Institute of Chartered Accountants

  • CPA Australia


  • MBA



ComplianceDirect Consulting Limited (2016 – now)

Co-Founder and Managing Director

  • Established the compliance consulting company in Singapore to provide compliance and control advisory and support services to banks, licensed corporates and financial services companies.

Standard Chartered Bank (2014 – 2017)

Managing Director (2015-2017)

Global Head of Compliance Assurance

Central Compliance, Group Compliance

  • Responsible to uplift, build and resource the created function, to support the Group Compliance to deliver its overall compliance agenda, and to discharge its assurance obligations, as a 2nd line control function;

  • Managed and developed the compliance assurance framework, policies, procedures and processes to support (1) compliance management information; (2) compliance risk management (i.e. compliance risk assessment and risk analytics); (3) compliance process & risk control (i.e. compliance operational risk control and regulatory obligations management) and (4) compliance assurance review;

  • Managed a team of compliance professionals at the global office and regional compliance review teams (i.e. GCNA, ASA, AME, Europe and Americas), to execute the overall compliance assurance framework and review programme.

Managing Director (2014-2015)
Senior Compliance Advisor, Business Legal & Compliance Governance
Group Legal & Compliance, Client Segments

  • To provide compliance advisory and support to Group Compliance regarding compliance risk and governance processes and initiatives.

The Bank of New York Mellon (2007-2013)

Managing Director
Head, Compliance & Ethics, Asia Pacific

  • Responsible and built a team of professional compliance officers to provide compliance advisory, oversight and support to BNY Mellon business groups (i.e. asset servicing, corporate trust, treasury service, global markets, global collateral services, wealth management, global client management group) and business partners (i.e. technology services group, human resources, finance) across the branches and representative offices in 14 locations – Bangkok, Beijing, Hong Kong, Jakarta, Kuala Lumpur, Manila, Melbourne, Mumbai, Seoul, Shanghai, Singapore, Sydney, Taipei, Tokyo;

  • Supervised the establishment of the APAC AML/CFT and sanctions compliance function (an integral part of compliance and ethics) and the implementation of a consistent AML surveillance transaction monitoring review programme across the region. Set-up the APAC AML/CFT oversight committee and served as its chair;

  • Instrumental in setting up and driving the APAC Risk Oversight committee and served as co-chair until the regional chief risk officer was appointed in 2010. Also, served as the Compliance representative and member in various regional and country risk and governance committees and business acceptance committees.


Citi Bank N.A (2014, 1998-2007)

In-Business Control (“IBC”) Project Manager, Asia Pacific Consumer (2014)
Seoul, South Korea – Seconded to Citibank Korea Inc.

  • To provide advisory, guidance and support to the local IBC team on a short-term assignment, to further strengthen the overall efficiency of the IBC structure, internal control processes and governance.

Regional Compliance & Control Director (2000-2007)          
Global Consumer Group, Asia Pacific

  • Formulated the framework, policies and procedures to support the wealth management (investment, treasury and insurance) products & sales compliance and control programme; built a team of investment compliance officers to provide compliance advisory and support to the wealth management businesses across the region;

  • Led and managed the mergers and acquisitions activities for Asia Pacific consumer compliance function in the region;

  • Led the “new-to-region” product approval process through the Regional Wealth Management Product Review committee.

Country QA Head, Singapore (1999-2000)
Global Corporate & Investment Bank | Global Consumer Bank

  • Managed the integration process of the combined corporate and consumer quality assurance (“QA”) departments and ensure seamless and consistent execution of control practices across GCIB and GCB;

  • Designed and automated the entire compliance and control self-assessment testing, submission and issue tracking processes by implementing an integrated system, being the “first-of-its-kind” in the bank.


Quality Assurance & Internal Control Head, Singapore (1998-1999)
Global Corporate & Investment Bank

  • Developed a risk-based QA review schedule that covered business and operations in custodial services, trade operations, corporate finance, syndicated loan processing, treasury front office and operations, products & marketing units in Singapore and the regional cash processing hub;

  • Led the Business Risk and Compliance committee and responsible to maintain an effective issue tracking and escalation process;

  • Supervised the management of internal control functions (i.e. nostro account reconciliation process, trade confirmation, general ledger accounts proofing).


Standard Chartered Bank (1996 – 1998)
Senior Auditor

Group Audit, Asia

  • Regional auditor responsible for on-site audits covering the corporate banking (including financial institutional banking), markets (treasury, investment and merchant banking) and personal banking in Asia.


Citibank N.A. (1993 – 1996)

Senior Auditor
Corporate Audit, South Asia

  • Regional auditor responsible for on-site audits of Citibank’s operational and regulatory compliance in Brunei, Indonesia, Malaysia, Singapore and Thailand covering custodial services, regional cash processing, corporate loans and trade services, corporate finance & capital markets, offshore booking, treasury, equity investments, liability products, credit card operations, general services, quality assurance, private banking operations and fiduciary (corporate and private banking).