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.
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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)
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​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
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​Experience
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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)
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​ 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.
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​ 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
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​ 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
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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
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​ 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
Diana Che
Lead Consultant
Qualifications
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​​Member of Australia Certified Practising Accountant (CPA)
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HKIB Certified AML and Compliance Professional
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​Education
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​​The University of New South Wales, Australia
Bachelor of Commerce
Majors: Accounting and Information Systems
​Experience
​The Bank of New York Mellon (2011 -2023)
​Director, Head of Compliance Hong Kong Branch and Taipei Branch
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Held responsible for compliance matters of BNY Mellon businesses (including asset servicing, corporate trust, treasury services, global markets, wealth management) in Hong Kong and Taiwan
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Managed the local compliance teams to provide compliance advices, compliance monitoring, personal securities trading monitoring, compliance training, liaison with the SFC/HKMA, licensing, AML/CFT, Outsourcing, manage HKMA inspections and regulatory reviews, suspicious transaction reporting, etc.
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Acted as Money Reporting Laundering Officer (MLRO)
The Bank of New York Mellon (2008 -2011)
Senior VP, Regional AML Compliance and Sanctions Coordinator
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Enhanced / Strengthen the AML/CFT and surveillance transaction monitoring process review across APAC, including the implementation of Global AML transaction monitoring system
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Provided Sanctions Compliance Advisory & Support and ensure country has effectively implemented the proper control process in accordance to our corporate policy and any specific country sanctions requirements.
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​Citibank N. A Singapore (2005-2008)
Senior Vice President, Regional Compliance and Control, Retail Banking Wealth Management Products & Sales
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Provided regional compliance support / oversight to consumer businesses (covering both Onshore and Offshore propositions) vis-a-vis Regional Wealth Management initiatives, through all Sales & Distribution channels (e.g. Branches, Internet, Telephone, Direct Sales, etc.) in all countries within GCG Asia Consumer franchise.
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Instituted a sound and robust Investment Products Sales Surveillance and Monitoring Process (including reviewing Surveillance Reports parameters, Mystery Shopping, Customer Complaint Handling process etc.).
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Citibank N. A Singapore (2001-2005)
Vice President, Investment Compliance Officer for Retail Banking Wealth Management Products & Sales Singapore
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Held responsible for investment compliance matters for the consumer banking business in Singapore
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Provided compliance advices, compliance monitoring, compliance training, corporate governance, etc. and liaison with the MAS​
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Citibank N. A Singapore (1998 – 2001)
Quality Assurance (QA) – Corporate & Investment and Global, Consumer Banking
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Conducted independent review of businesses to evaluate the effectiveness of controls in places.
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Identified areas of improvement, recommended appropriate action plans to rectify control lapses and verified proper implementation of action plans
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Implemented the automation of compliance and control self-assessment process
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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.
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​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.
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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.
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​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.
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​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.
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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).
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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).
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