
Professional Consulting Team
Hong Kong Team
Benny To [CFA, CPA (US), LLM, MSc]
Co-Founder & Managing Director

Benny is a seasoned compliance professional with more than 28 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.
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 recognized lecturers for the accreditation of professional wealth management courses in Hong Kong, provided training to 4,000+ frontline employees in the largest Chinese banks.
Qualifications
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Charter Holder of Chartered Financial Analyst (CFA)
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Member of American Institute of Certified Public Accountants (AICPA)
Education
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University of Wisconsin – Madison (USA)
Bachelor of Business Administration
Majors: Accounting, Finance and International Business
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City University of Hong Kong
Master of Science – Banking
LLM – International Business Stream
Experience
ComplianceDirect Consulting Limited (2016 – now)
Co-Founder and Managing Director
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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
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Held 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
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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.
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Acted as Money Reporting Laundering Officer (MLRO)
Coutts and Co Limited (2008-2009 and 2011-2012)
Director - Compliance
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Held responsible for compliance matters for Coutts’ private banking business in Hong Kong
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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
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Held 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.
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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
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Held responsible for compliance matters for the private banking business in Hong Kong and product compliance for private banking business in Asia
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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
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Held responsible for investment compliance matters for the consumer banking business in Hong Kong and Macau
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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
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Conducted onsite examinations, offsite reviews and ongoing supervision on local and international banks
Bank of East Asia Group (1994-1997)
Assistant Manager – Treasury
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Executed trades in money market and foreign exchange markets
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Managed the liquidity position, trading positions and provided general treasury management for the bank
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.
Qualifications
Associate AML Professional (AAMLP), Hong Kong Instituion of Banks
Education
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
Experiences
HSBC (2015 - 2019)
Head of Reputational Risk & Customer Selection, Financial Crime Compliance, Asia Pacific
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Held 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
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Advised financial crime compliance and investigation 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
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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
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Held 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
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Reformed and institutionalized due diligence teams from various business functions into one team serving all corporate, investment banking and global markets divisions
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Completed successfully all remediation work by bringing all customers in proper review cycles enhancing overall portfolio risk profiles
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Held regional responsible for due diligence teams in 13 locations, comprising the provision of operational support, quality control and process standardization
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Managed and/or participated in steering committees and working groups to enhance policy, productivity, quality assurance, due diligence systems
Coutts Asia (2010 - 2012)
Head of Operational Risk, Asia
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Held responsible for regional leadership and senior management of Coutt’s operational risk management objectives and directions for alignment regional strategic growth plans
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Provided operational risk reviews on products, business plans, transactions and change initiatives
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Established product review group consisting of and business representatives, allowing speedy and safe product roll outs
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Implemented group policies, internal control environment certification and scenario analysis, including Sarbanes-Oxley 404
UBS Hong Kong (2019-2010)
Director, Compliance, Private Bank
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Advised compliance matter in suitability, product rollout, business strategy
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Created and implemented policies and procedures to enhance compliance of legal and regulatory requirements for the purpose of protecting the reputation of the firm
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Assisted in the handling of routine regulatory reviews and enquiries
National Australia Bank Limited (1996-2009)
Compliance and Operational Risk:
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Established compliance policy and control frameworks in the areas of regulatory change capture, reporting platform for management oversight, project management, and regulatory engagement
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Developed and conducted compliance training framework sessions for all staff on compliance regulatory and business requirements including regular fit & proper assessments
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Provided 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
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Provided 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.
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Analyzed customer information MIS and portfolio (pricing and risk concentration) and streamlined marketing support and business strategic requirements
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Implemented effective cost management related to marketing expenditures and successfully utilised HK model to support neighbouring centers
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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
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Established Western Union’s first agency network in China in 1995
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Established Western Union international’s money transfers franchise and agency management in Asia Pacific region and helped business development
Singapore Team
Priscilla Chin
Co-Founder & Managing Director
Qualifications
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Qualified member of Singapore Institute of Chartered Accountants
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CPA Australia
Education
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MBA
Experience
COMPLIANCE & CONTROL
ComplianceDirect Consulting Limited (2016 – now)
Co-Founder and Managing Director
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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, Global Head of Compliance Assurance & Central Compliance, Group Compliance
(2015-2017)
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Held 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 second line control function;
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Managed and developed the compliance assurance framework, policies, procedures and processes to support (i) compliance management information; (ii) compliance risk management (i.e. compliance risk assessment and risk analytics); (iii) compliance process & risk control (i.e. compliance operational risk control and regulatory obligations management) and (4) compliance assurance review;
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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, Senior Compliance Advisor, Business Legal & Compliance GovernanceGroup Legal & Compliance, Client Segments (2014-2015)
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Provided 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 of Compliance & Ethics, Asia Pacific
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Held 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;
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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;
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Set up and drove 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 (1998-2007 & 2014)
In-Business Control (“IBC”) Project Manager, Asia Pacific Consumer, seconded to Citibank Korea Inc. (2014)
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Provided 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
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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;
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Led and managed the mergers and acquisitions activities for Asia Pacific consumer compliance function in the region;
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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
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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;
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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
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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;
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Led the Business Risk and Compliance committee and responsible to maintain an effective issue tracking and escalation process;
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Supervised the management of internal control functions (i.e. nostro account reconciliation process, trade confirmation, general ledger accounts proofing).
INTERNAL AUDIT
Standard Chartered Bank (1996 – 1998)
Senior Auditor, Group Audit, Asia
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Held regionally 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
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Held regionally 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).