Samantha Pelosi is a Senior Director in the Risk, Regulation, and Compliance Practice of Guidehouse’s Financial Services Segment. Samantha possesses nearly 25 years of legal, compliance, and policy experience in both the public and private sectors. She is a global authority on anti-money laundering, payments, and blockchain/distributed ledger technology.
Samantha advises on a variety of engagements, including licensing, risk assessment and management, gap analysis, compliance programs, procedures, and internal controls, independent testing, remediation efforts, investigations, fraud prevention and recovery, operations, selection, customization, and integration of technology systems, and product development. She works with large global banks, regional banks, money transmitters, payments system operators, cryptocurrency and digital assets companies, central banks, regulators, international standard setters and development organizations, industry associations, fintech and regtech firms, and multinational corporations.
Prior to Guidehouse, Samantha drove the strategy, policy advocacy, and thought leadership initiatives in financial crime compliance, payments/cash management, and emerging technology at transaction banking association BAFT. Samantha produced tools widely recognized as industry best practice, including a playbook for obtaining and maintaining correspondent banking accounts, a model indemnity agreement to secure the return of fraudulently transferred funds, and a framework for auditing blockchain solutions used in banking.
Samantha held senior positions at the Federal Reserve Board following the financial crisis and FinCEN following 9/11. At the Board, she managed a team that analyzed emerging payment methods such as mobile and cryptocurrency, oversaw Federal Reserve Bank operations, and launched the faster and secure payments task forces. She also drafted and implemented regulations under the Dodd-Frank Act governing remittance transfers, check clearing and settlement, and debit card interchange and routing. At FinCEN, Samantha wrote regulations implementing the USA PATRIOT Act, brought high-profile enforcement actions for Bank Secrecy Act violations, and negotiated financial intelligence information sharing agreements between FinCEN and its foreign counterparts.
As the global head of regulations and compliance, Samantha built international money transmitter Ruesch’s compliance function from scratch to prepare it for sale. After Ruesch’s acquisition by Travelex, she integrated the compliance teams, programs, and systems to create an efficient and effective worldwide function. Samantha began her career at the law firm Morrison & Foerster, where she handled international project finance, corporate, sanctions, and export control matters.
J.D., University of Virginia School of Law B.A., Political Science, Duke University
State of Maryland Bar District of Columbia Bar
Membership and Activity Information
Governance Council, Travel Rule Information Sharing Alliance Founding Member, Chief Member, Global Association of Women in Payments