Portrait of Gary E. Peterson

Network partner · IMAG

Gary E. Peterson

Compliance and AML programme designCulture and governance changeBoard advisory

Profile

Gary Peterson is a highly experienced global financial services professional who understands compliance from a variety of perspectives. He has served as the General Counsel of Midland Bank plc in the USA and as Chief Compliance Officer and AML Director for HSBC USA. He has also served as interim Chief Compliance Officer for Western Union Business Solutions, a major global payments provider. As a board director, he has served as Chairman of both the Compliance and Risk Committees at a significant US regional bank.

His areas of advisory specialisation are cross-organisational cultural and governance change, multi-area risk oversight and designing and implementing risk and compliance programmes which deliver sustainability and continuous improvement. He is most widely recognised as the founder and President of IMAG, an advisory firm he founded in 1993 specialising in culture change across the lines of defence. As an advisor, he has counselled the boards and senior management of over 30 of the largest global financial institutions, and most recently leads an advisory group at IMAG that assists management teams transition from traditional to AI platforms.

He frequently advises global management teams on strategic planning initiatives relating to implementing the culture of compliance, governance, technology, advanced analytics, cryptocurrencies, global sanctions, lines of defence, operational controls, third-party relationships and the management of enterprise reputational risk. Gary is a summa cum laude graduate of Lehigh University and received his Juris Doctorate from Case Western Reserve University School of Law. He is a member of the New York State and Federal bars.

Areas of expertise

  • 01Compliance and AML programme design and governance
  • 02Culture, conduct and governance change across the lines of defence
  • 03Board and senior management advisory on risk and compliance
  • 04Multi-area risk oversight and committee governance
  • 05Global sanctions and regulatory strategy
  • 06Technology, advanced analytics and AI platform transition
  • 07Enterprise reputational risk management
  • 08Third-party and operational controls

Selected engagements & achievements

  1. 01

    Served as General Counsel of Midland Bank plc in the USA.

  2. 02

    Served as Chief Compliance Officer and AML Director for HSBC USA.

  3. 03

    Served as interim Chief Compliance Officer for Western Union Business Solutions, a major global payments provider.

  4. 04

    Served as Chairman of both the Compliance Committee and the Risk Committee of the board of a significant US regional bank.

  5. 05

    Founded IMAG in 1993, an advisory firm specialising in culture change across the lines of defence, and continues to lead it as President.

  6. 06

    Advised the boards and senior management of over 30 of the largest global financial institutions on compliance, governance and risk matters.

  7. 07

    Leads an advisory group at IMAG assisting management teams in transitioning from traditional to AI platforms.

Core belief

“Lasting compliance performance comes from changing the culture across the lines of defence, not just the policy on paper. Governance and risk programmes must be designed and continuously improved so that they remain sustainable as organisations, technology and regulatory expectations evolve, with senior management and the board actively engaged in that oversight.”

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