1. VIA ELECTRONIC MAIL
17 August 2009
Association of Certified Anti-Money Laundering Specialists™
Brickell Bayview Center
80 Southwest 8th Street
Suite 2350
Miami, FL 33130 USA
E-mail: pnino@acams.org, editor@acams.org
Attention: Education and Training Department
RE: 2009 ACAMS AML PROFESSIONAL OF THE YEAR AWARD NOMINATION ™
Dear Sir or Madam:
We are nominating Joel R. Mullett, CAMS® to be recognized as the most outstanding professional in the AML
field from August 2008 - July 2009. Joel’s accomplishments within Bank of America are many and varied, and
have directly resulted in achievement of strategic corporate goals related to AML.
Joel heads up the customer due diligence and risk management program for all Bank of America Global
Wealth & Investment Management businesses world-wide. In that role, he has proven to be an innovator with
the ability to identify the most relevant risks to the organization and make significant improvements to ensure
management understands and that reasonable steps have been taken to manage those risks with a holistic
view. His energy and focus have moved efforts ahead through the most challenging period of time for financial
institutions anyone can recall.
We’d like to share a few examples of why we feel this is a deserving recognition for Joel’s contribution.
Leadership in Audit and Exam Management
During the relevant time period, Joel Mullett was responsible for AML audit and exam management for the
Global Wealth & Investment Management businesses, which were audited by numerous organizations,
including FINRA, OCC, and comprehensive Corporate Audit reviews of each line of business’ compliance and
adherence to corporate standards. In this regulatory climate, it goes without saying that exams were notably
more comprehensive with greater focus on even potential failure points in the existing program. In spite of this,
there were no AML issues noted in any report from any line of business. This significant achievement was due
in large part to Joel’s tireless management of the exams and effective rebuttal of any potential or perceived
exceptions. In fact, Joel was recognized by executive management for his relentless dedication to exam
management and was awarded the Bank of America Sprit Medallion Award for the Second Quarter in 2008.
Further, a recent evaluation of the program by well-known, independent consultant noted that the program
“continues to be one of the most actively and successfully reformed areas of compliance, with continual, on-
going improvements” and Joel was recognized by the consultants as a “knowledgeable, competent, and well-
versed subject matter expert.”
Enterprise and Industry-Changing Process Innovation and Improvement
Joel is known around the enterprise for his thought leadership and ability to innovate through just about any
roadblock, whether it be technology-related, resource constraints, or limitations in the current status-quo within
our industry. If no solution is available in the marketplace, Joel pushes our suppliers to customize products for
the needs of the division and, as a result, has been asked to sit on two (2) advisory councils with major data
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2. analytics suppliers of the industry. He pioneered a customized product to verify entity customer records
through an unprecedented batch process that utilizes rules-based fuzzy logic and sources both secretary of
state as well as people data to evidence the legal status of small operating companies with d/b/a’s, trusts,
estates, partnerships, and other types of personal holding companies. The business enjoyed a significant cost-
save in people costs and reductions in the defect rates of entity records.
In addition, Joel was also responsible for the GWIM-wide effort to implement a process to measure 100% of all
GWIM customer records on a monthly basis, based on new account opening, for adherence to the Customer
Information Program (CIP), and, while doing that, ensure an enterprise-mandated 99.6% completeness metric
was supported by a sustainable process by October 1, 2008 to meet commitments made to our primary
regulator. Under Joel’s leadership, tens if not hundreds of associates from around the enterprise were
influenced to provide assistance in analyzing technology issues, training issues, and implementing action plans
to address numerous peripheral needs in order to achieve this goal. As a result, GWIM was the first BAC line of
business meet the “Go-to-Green” goals, with the side benefit of resolution to some long-standing technology
issues. All of this was delivered ahead of schedule.
Thought Leadership within the Technology and Transition Groups
During the relevant time, Joel also was GWIM’s KYC (Know Your Customer) Process Owner. This role required
Joel to align the KYC tools to AML Policy, and streamline processes for consistency across all lines of business.
In a vast organization, this was no small task, yet Joel drove improvements in stability to the shared technology
platform, formalized a production support program and, through years of effort, relentlessly and tirelessly
raised awareness and mobilized efforts resulting in the drastic improvement to a now stable platform that is
nearly error-free. He also designed a KYC Datamart Tool with audit trail functionality, enabling great
convenience in providing complete records to the audit teams and regulators. The remarkable thing about this
is he does not have a technology background. He immerses himself in a process, studies the situation with
attention to detail unlike many others, and in the end establishes himself as an expert in just about any topic.
Joel also was responsible for seamless integration of the U.S. Trust and LaSalle businesses in 2008, and now
Merrill Lynch this year and through 2010. Each of these acquisitions brought its own set of problems and
challenges. Joel has managed the on-boarding and customer due diligence aspects of each of these transitions
with stunning success. Consistent with his approach to everything – constantly raising the bar - the conversion
specifications he developed exceeded earlier precedents set by enterprise and regulatory expectations resulting
in conversion and integration dates that were a non-event.
Transformation from AML Customer Due Diligence to Holistic Customer Risk Evaluation
While much of Joel’s work over the last few years has resulted in stability in the on-boarding and customer due
diligence procedures, he did not rest with that accomplishment. He has switched gears now in his new role as
of last October to bring awareness and laser focus to the most significant customer risks facing the wealth
management businesses. Joel has worked to improve enhanced due diligence procedures, demanded better
information and results from our vendors, and led the charge in corralling what the bank considers to be the
categories of customers presenting the highest potential risks. He has brought consistency to how risk
indicators in the portfolio are to be decisioned across all lines of business through a formalized process. His
efforts allow the division to demonstrate executive-level understanding, with specificity, to the inherent risk in
the portfolio and to collectively gauge the on-going tolerance for assuming customer risk issues at the time of
on-boarding. He has recognized that, while the AML program may have led the way with respect to minimum
guidelines and requirements for who we do business with and how we prove we know our customers, the time
has come to also include a comprehensive risk management approach that considers operational, legal,
geographic, supervisory, and, most importantly, reputational risks that could at any moment bring down an
enterprise.
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3. In Summary
In summary, Joel is a widely-known and trusted officer of Bank of America, whose judgment and leadership has
been recognized across the organization. His passion is unrivaled, and everything he does is, at heart, to make
this bank a better place for its customers, shareholders, associates, and, as a result of this, carries an
incremental contribution to the stability and confidence of the global financial markets. He has earned the
respect of both executive management and the associates who report to and support him.
He has, without a doubt, made the most significant contribution to the division’s program during a very
challenging transitional period, and, in short, we cannot think of a more qualified and deserving person to be
designated “ACAMS AML Professional of the Year.” We welcome the opportunity to speak with you further
about this nomination.
With sincerest thanks for your time and thoughtful consideration,
Tracie Campbell Kosakowski, Esq., CAMS® James Foskett, CFE, CAMS®
ACAMS Member ID: 139759 ACAMS Member ID: 85659
Senior Vice President Senior Vice President
Special Counsel for Customer Risk Management Customer Risk Event Management
Wealth Management AML Supervision and Governance Wealth Management AML Supervision and Governance
Bank of America Corporation Bank of America Corporation
111 Westminster Street 100 Federal Street
Providence, RI 02903 Boston, MA 02110
Phone: 401-398-8654 Phone: 617-434-6497
tracie.c.kosakowski@bankofamerica.com james.foskett@bankofamerica.com
Contact Information for our Nominee:
Joel R. Mullett, CAMS®
ACAMS Member Number: 124141
Global Head of Customer Due Diligence & Risk Management
Wealth Management AML Supervision and Governance
Bank of America Corporation
Registered Principal, Banc of America Investment Services, Inc.
100 Federal Street
Boston, MA 02110
Phone: 617-434-8622
joel.r.mullett@bankofamerica.com
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