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Dominion’s History and Our Role in Shaping AML Compliance

Dominion has had a unique and pivotal impact on the history of AML compliance and the establishment of today’s AML standards.

Dominion’s principals, Jon Glass and Pete Balint were hired by Riggs Bank in 2003 to build an AML program in response to OCC and Federal Reserve enforcement actions. The program’s weaknesses were discovered on the heels of several widely publicized media reports that a Riggs customer was associated with the one of the September 11, 2001 hijackers.  Those reports were later proven untrue, in large part to the work completed by Glass, Balint and others at Riggs.

While the media reports of a Riggs customer being involved in the September 11th attacks were unfounded, this event and subsequent revelations about other Riggs customers instigated the post PATRIOT Act era of AML compliance enforcement.

Through the work of what is now the Dominion team, and several other key Riggs AML officers, the improved AML controls established at Riggs in 2003 uncovered the corruption scandal involving the government of Equatorial Guinea, that country’s president and a senior Riggs banker.

That event caught the attention of the Senate Permanent Subcommittee on Investigations, and in July 2004 the Subcommittee held a hearing during which Riggs and its regulators were informed in very clear terms that AML compliance failures of this kind would not be tolerated and that deficiencies and weaknesses among other financial institutions needed to be identified and addressed.  Thus in 2004 a new, much more intense focus by regulators on AML compliance was launched and has continued for the past 11 years.

The experience gained by Dominion’s principals during those two intense years (2003 – 2005) cannot be replicated.  That perspective provided us with a true understanding of what it is like to sit in the seat of AML executives.  This is what we mean when we say, “we see AML compliance from our client’s point of view.”

Featured Case

Investigation Training


Dominion’s FIU development team implemented a two stage-training program. Within a month the FIU was completing investigations and filing SARs commensurate with industry best practice.

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