Richard N. Pagnotta, Sr.

Richard N. Pagnotta, Sr. currently holds the dual role of Chief Compliance Officer for both Interaudi Bank and Ameraudi Asset Management for their offices based in both New York and Miami. He has been in these roles since August 2024.

Prior to his current role, Mr. Pagnotta was a Senior Vice President, Chief Compliance Officer (“CCO”) and the BSA Compliance Officer for the New York Branch of Itaú Unibanco S.A., South America’s largest bank by total assets, employing approximately 100,000 employees worldwide, responsible for the day-to-day management of the Compliance Department, overseeing the Risk Management of BSA/AML and OFAC Compliance, as well as Corporate Compliance since 2012. He was appointed Deputy General Manager & CCO in January 2019, and ultimately the position of Interim General Manager in October 2019, until after eleven years, he decided to step down from his position in November 2023.

During Mr. Pagnotta’s eleven year tenure in New York he was solely responsible, led and oversaw several significant and successful project implementations that included BSA/AML remediation efforts to bring the Branch’s AML compliance program from being in distress to both adequate and satisfactory in the eyes of its regulators; moving its back office, middle office and IT operations to the bank’s Operational HUB located in Lisbon, Portugal of which he oversaw; and finally, in February 2020, led all aspects, including legal and regulatory, of the closing and liquidation of the New York Branch, while simultaneously leading all of the same aspects of the opening of a new Miami Branch of Itaú Unibanco S.A., where all former New York Branch operations and assets where transferred. Mr. Pagnotta relocated from New York to Miami for this transition for one year, and maintained his position as Interim General Manager from New York, working remotely and traveling back-and-forth to Miami, as well as to Lisbon several times throughout the year.

Richard is a highly seasoned compliance professional and regulatory/anti-money laundering compliance specialist, well-known in the New York international banking community with extensive experience in building, managing, and maintaining compliance programs for foreign banks, as well as managing the entire regulatory authority examination process for foreign banks since the International Bank Supervision Act of 1991 was enacted.

Richard has extensive international banking experience, heavily concentrating on BSA/AML, OFAC and Corporate Compliance for the past 25 of those years. Prior to working at Itaú Unibanco S.A., he built out the BSA/AML and OFAC Compliance Program of China Merchants Bank Co., Ltd., New York Branch. He successfully built all initial Compliance Programs for the Branch, including all applicable regulatory policies and procedures, ensuring all activities in the U.S. (front office and support groups) complied with all applicable rules, regulations, and laws. His expertise in implementing formal written comprehensive policies and procedures, incorporating compliance risk management, developing both regulatory and AML training programs, developing comprehensive compliance testing and monitoring programs, and implementing and maintaining automated AML systems for Customer Due Diligence, Enhanced Due Diligence, Transaction Monitoring, OFAC, FinCEN 314(a), and MIS Reporting compliance make him an asset to his colleagues and clients in the international banking community.

Previously, Richard was Head of Compliance North America at Eurohypo AG, New York Branch where he led the overall management and day-to-day operations of their Compliance programs in New York, Chicago and Los Angeles. He also worked at CIBC World Markets Corp. where he was an Executive Director and Compliance Officer and, among other things, responsible for the development of their Compliance Risk Assessment Program. Prior to that, Richard was a Vice President and Compliance Officer at Mizuho Corporate Bank, Ltd., where he was responsible for the development, implementation and execution of their Compliance Testing and Monitoring Program, the first of its kind at the time. He started his career at Banco Nacional S.A., New York Agency (a Brazilian foreign banking organization) where he spent 15 years in various positions and ultimately as their Manager of Operations. He attended St. John’s University and received his Certified Compliance Regulatory Professional (“CCRP”) certification through Pace University’s Lubin School of Business in partnership with the Association of International Bank Audit and Compliance Professionals, Inc. (“AIBACP”), where he is a member of the Board of Directors and Treasurer. Richard was awarded a Certificate of Recognition in July 2015, for being one of the pioneers of the Pace University CCRP Program and for playing an integral role as a member of the initial Curriculum Committee that developed the Program. Richard had occasionally lectured as a Subject Matter Expert (“SMA”) to students enrolled in the CCRP Program, has participated as a panelist on Correspondent Banking at the Florida International Bankers Association (“FIBA”) Annual Anti-Money Laundering Conference, and was an active member of the Institute of International Bankers (“IIB”) and had sat on both their Compliance Officers Committee and Legislative and Regulatory Policy Committee during his tenure in New York.