Sandra L. Bograd
SPECIAL ADVISOR (COMPLIANCE & SANCTIONS RISK MANAGEMENT)
Based in New York, Sandra Bograd has been a Special Advisor to Optima Strategies since 2014. She provides advice to corporate, governmental, NGO and multilateral institutions and organizations on the design and activation of best practices through effective programs of governance, sustainable business practices and compliance with expected social and ethical normative behaviors in global business operations (ESG). She has extensive experience in the development of programs to affirmatively mitigate the risk of corrupt behaviors in global organizations.
Ms. Bograd is a Lecturer in the Insurance Management Masters program at Columbia University. Ms. Bograd’s course provides corporate executives with an understanding of the legal and regulatory ecosystem of complex financial services such as those found in global insurance, banking and investment organizations. Her course is presented form the perspective of proper ESG risk management and regulatory interaction.
Ms. Bograd previously held the position of Senior Vice President and Chief Global Compliance Officer for New York Life International, LLC. In that role she was responsible for the design, strategy, development, implementation and management of legal compliance professionals and corporate governance programs throughout emerging markets in Asia and South America with a particular emphasis in the Peoples Republic of China and India. Her work included partnering with joint venture partners and financial services regulators in development of an insurance regulatory infrastructure in new cities and territories on subject matters such as advising the Indian Insurance regulator on the development of the initial set of Anti-Money Laundering (AML), Know Your Customer (KYC) and Conflict of Interest (COI) as applicable to insurance products and salespersons in India.
As an Associate General Counsel at Bank of America Corp Ms. Bograd was chief counsel and principal legal advisor supporting enterprise global financial crimes compliance as well as oversight of corporate transactional activity as related to financial crimes, FCPA, OFAC and national, state and international political law. In this role she covered all aspects of financial crimes, internal investigation and outside counsel oversight including Anti- bribery and Anti-corruption activities, Political Law as well as Economic Sanctions application and oversight. Ms. Bograd was principal legal advisor on issues associated with Iranian and Russian funds held in blocked accounts as a result of global economic sanctions and multi-lateral litigation.
As Assistant General Counsel with AIG, Inc., the parent company of American International Group Ms. Bograd was responsible for developing the company’s worldwide compliance programs around a number of anticorruption, antiterrorist financing and economic sanction program policies and procedures in the wake of the enactment of the U.S.A. Patriot Act and other global anti-terrorist financing regimes. Her work reached across the AIG global footprint, which at the time included operations in 144 countries and territories encompassing insurance, banking, investment, real estate and hospitality concerns.
While at AIG Ms. Bograd was responsible for the creation and implementation of the AIG Political Activities Policy and acted as legal advisor to the Corporate Affairs and State Relations Departments in their work with federal, state and international political activities and candidates. In that role Ms. Bograd had extensive interaction with the AIG Political PAC and the CV Starr Foundation (a charitable foundation) with respect to compliance with laws and regulations associated with corporate political activity, contributions, financing and economic sanctions exposures.
Ms. Bograd also held the position of Vice President of Ethics and Business Practices at Freddie Mac in McLean, Virginia, post conservatorship. She oversaw a team of professionals who managed and implemented the corporate ethics, anti-corruption, internal fraud and internal investigations programs to meet US Department of Treasury expectations. While at Freddie Mac, Ms. Bograd created and implemented a set of key risk indicators to capture behaviors that give rise to higher levels of operational and ESG risk.
Earlier in her career Ms. Bograd was a prosecutor in Newark New Jersey where she prosecuted fraud, organized crime and homicide cases at the trial level. After leaving government, service Ms. Bograd was engaged in the private practice of law where she specialized in representing corporations and individuals in regulatory and criminal investigations and corporate compliance issues. Ms. Bograd defended clients in regulatory inquiries and conducted internal investigations in the areas of fraud and abuse, money laundering, anti-corruption and government contracting as well as insurance fraud and environmental crimes.
Ms. Bograd received her B.A. from Rutgers University and her J.D. from Vermont Law School. She also attended the University of London, Birkbeck College where she studies International Business and Economics. Ms. Bograd has authored a number of articles featured in leading industry trade journals and general interest publications on topics associated with emerging markets, compliance cultures and combating corrupt behaviors in global business. A native of New Jersey Ms. Bograd has lived and worked throughout the United States, Europe and Asia.
She has been a frequent speaker at global summits in the United States and Europe.
Ms. Bograd has been named as one of New York City’s Top Women Attorneys for her work in Corporate Compliance law.