Vladimir Berezansky

Mobile: +7 985 773 4176 Personal e-mail: [email protected]

Career overview:

 Experienced international lawyer and compliance professional specialising in banking and financial regulatory compliance, due diligence, and corporate governance with extensive experience in EMEA jurisdictions – specifically, Russia / CIS, Baltic, Balkan and East European markets;  Senior managerial roles (department head) for Swiss banks UBS, l’Union Bancaire Privée (UBP), UBS and VTB Capital (investment bank for Russia’s second largest banking group);  Significant liaison experience with national financial institution regulators and self-regulatory organisations (SROs): banking, financial services, securities exchanges, capital markets, and AML / KYC / CFT;  Professional accomplishments include launching and/or restructuring regulatory compliance and corporate governance infrastructures of several multinational holding companies, including: MDM Financial Group, a top- tier Russian bank; Linebrook Limited, a multinational industrial group (holding); and VTB Capital, a major Russian investment banking platform;  Native English; fluent Russian; business proficient in French and German.

Specific Expertise / Professional Specialisations:

 Interface (liaison) with major EMEA banking, financial markets and AML regulators, including: FCA (FSA), PRA (UK); BaFIN (Germany); FINMA (Switzerland); DNB (Netherlands); CySEC (Cyprus); RosFinMonitoring and Central Bank (Russia); ESMA; EUROPOL / INTERPOL;  Russia referent for UBP to FINMA; provided regular updates, consultation on new Russian legislation & regulations; business intelligence on Russia / CIS / Baltics / CEE;  Designed, launched and supervised ‘green field’ compliance infrastructure (global control room; comprehensive set of protocols & procedures for channelling public- and private-side information, etc.) for VTB Capital (Moscow), a full-service investment bank, under duress conditions of Arrow Review by (then) FSA of VTB Capital’s London operations;  KYC enhanced due diligence on ‘difficult’ cases, including PEPs;  AML-orientated reviews of questionable client account activity, including advice as to when discretionary SARs might be appropriate;  Trade sanctions screening and analysis of ultimate beneficial owner (UBO) / interlocking ownership issues;  Identifying red flags suggestive of abuse of off-shore vehicles, including specifically for structured off-shore Russian wealth (see: http://www.kaltura.com/tiny/xk0jx);  Analysis and consultation on banking and financial services innovations / technological (fintech, regtech, blockchain technology, bots / AI) and change management;  Advise clients on new and anticipated changes to FCA and other new / recently amended regulatory regimes; e.g., MiFID II, EU AML4 Directive; GDPR; Basel II & III; SMR & Certification Regime; BEPS & CRS (OECD taxpayer disclosure initiatives), including necessary revisions to internal protocols and procedures and training modules.

Professional Qualifications & Affiliations:

 Washington, D.C. Bar Association (professional licence to practice law), USA  FSFM 1.0 (Broker-Dealer) Certification, Russia

Work Experience:

2016 – 2017: Thought Leader, Compliance Practice (Director, Assurance) EY LLP London, UK

 Scope of financial regulatory Compliance thought leadership remit expanded from Russia/CIS to entire EMEA territory

2013 – 2015: Leader, Compliance Practice (Director, Assurance) EY (Ernst & Young) CIS B.V. Moscow, Russia

 Broad spectrum of Compliance consulting support focused primarily on Russian / CIS, Baltic and Eastern European financial institutions adapting to extraterritorial (UK / US / EU) regulatory regimes and implementing global best practice standards.

2011 – 2013: Head of Legal and Compliance, Russia/CIS UBS Bank Moscow, Russia

 Supervise in-house Legal and Compliance functions for the full range of UBS Bank’s Russian operations – including Investment Banking, Research, Equities & FICC trade platforms, corporate & retail banking, and wealth management / private banking activities.  Effectuate merger of Internal Control & Compliance departments.  Manage UBS Bank’s relationships with Russian banking & financial regulators and SROs.  Design, launch and maintain UBS Moscow’s compliance infrastructure for implementing newly enacted Russian Law on Insider Information & Market Manipulation.  Ensure overall adherence to applicable UK and Swiss banking & financial compliance standards. Develop policies and procedures for implementing newly enacted Dodd-Frank requirements for registering OTC derivatives (swaps) dealers (Title VII), and for Volcker Rule restrictions on proprietary trading (Title VI).  Develop policies and procedures in preparation for FATCA registration as participating foreign financial institution (PFFI).  Full compliance support for largest M&A transaction in Russia for 2012.

2009 – 2011: Head of Compliance VTB Capital Moscow, Russia

 Create and implement (start-up circumstances) robust Compliance regime consistent with Russian legal/regulatory requirements and internationally recognised best practices.  Integrate Moscow Compliance practices with those of VTB Capital's FSA-registered UK entity (and other market jurisdictions worldwide).  Supervise launch of Moscow compliance control room from inception to implementation and operational monitoring.  Liaison with VTB Capital London Legal & Compliance functions during FSA Arrow Reviews and other regulatory enquiries. Build and manage Moscow’s Compliance team.

2007 – 2009: Head of Compliance for Russia / CIS and Eastern Europe L’Union Bancaire Privée (UBP) Geneva, Switzerland

 Account-opening, monitoring and transactional due diligence for UBP’s significant Russia / CIS & Eastern European clientele, including structural (legal and compliance) analysis of on- and off-shore structures, family offices, funds flows, and intra-group price transfer mechanisms.  Develop internal policies and procedures to apply Swiss Agreement on Due Diligence (CDB) and FINMA Anti- Money Laundering Ordinance (AMLO-FINMA) to Russia/CIS private banking and wealth management operations at UBP’s subsidiary Russian limited liability company.  Legal and administrative support for registration of UBP’s Russian limited liability company and Moscow office operations, including legal and compliance support.

June – December 2006: International Compliance Officer, Aton Capital Group Moscow, Russia

 Comprehensive implementation & support for modifications to Aton’s compliance policies and practices, incorporating applicable legal/regulatory regimes of the Russian Federation (FSFM), Cyprus (CySEC), United Kingdom (FSA), German Federal Republic (BaFIN) and the United States (SEC/NASD).

 Conduct formal, regulatory-mandated internal audits of Aton’s New York, London and Moscow offices in tandem with Internal Audit Committee.

June 2005 – May 2006: Chief Compliance Officer, Linebrook, Limited Nicosia, Cyprus

 Establish and maintain internal compliance policies and practices for vertically integrated industrial holding / managerial company.  Integrate corporate governance infrastructure implementing internationally recognised best practices, and ensure overall compliance with relevant jurisdictions including Cyprus, EU, UK, Russia and USA, and industry self- regulators.  Register in-house trading platform with CySEC. Design & implement internal compliance infrastructure (policies & procedures) for securities trading (corporate portfolio).

May 2004 – April 2005 Deputy Managing Director, Moscow Office The PBN Company, Moscow, Russia

 Corporate consulting to multinationals entering and/or operating in Russia/C.I.S. and emerging (second and third tier) regional corporates on issues including corporate governance, due diligence, financial institution regulatory compliance, mergers & acquisitions and corporate finance (capital markets).

March 2002 – March 2004 Director, International Legal & Compliance MDM Financial Group, Moscow, Russia

 Senior in-house legal and compliance officer for a major Russian bank. Creation and implementation of comprehensive (Russian and international) compliance regime – policies and practices – consistent with post- 09/11 changes to US, UK and EU regulations.  Represent Russian banking sector at Financial Institutions Compliance Benchmark Group (FICBG), pan-European self-regulatory organisation.  Organise and host visiting FATF delegation, pending removal of Russia from FATF ‘Black List’ of Non- Cooperative Countries and Territories.  Legal issues include: foreign (non-Russian) multiple trade agreements (ISDA, ISMA, SWAPs); legal restructuring of MDM’s cross-border group structure; integration of Russian and international compliance standards & practices.

Education:

 Lecturer in international and American law – graduate coursework in Russian law, Far Eastern State University (FESU), Vladivostok, Russia  Juris Doctorate, Washington College of Law, American University, Washington, D.C., U.S.A.  B.A. in Linguistics, Columbia College, Columbia University, New York, New York, U.S.A.

Personal:

 Citizenship: USA; Countries of Residence: Russian Federation & United Kingdom (co-located)

Numerous articles and frequent speaking engagements on topics including financial regulatory compliance in emerging market circumstances and recent technological developments in the banking and finance sectors.