Pavel Karusev

Experience

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  Linklaters

  Jul 2011 - Jun 2013

  Trainee lawyer

  Here I gained the basic knowledge about anti-corruption and anti-money laundering. I learned how to conduct due diligence and detect the relevant risks of non-compliance. I was performing legal researches, legal translations, drafting client emails, and due dilligence in the course of preparation for IPO, SPO, M&A, and structured financing deals. That was an exciting experience to work with a team of the high-profile professionals.

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  Pepeliaev Group

  Aug 2013 - Sept 2014

  Lawyer

  Advising banks and other financial institutions on compliance with applicable laws and regulations.

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  Trade Company MEGAPOLIS

  Sept 2015 - Jun 2019

  Expert (Compliance Department)

  Here I started to use my experience for devising compliance policies and procedures for the major privately-owned FMCG company with participation of the top cigarette manufacturers (Philip Morris International, Japan Tobacco Internatinal, Imperial Brands). Trade Company Megapolis holds ~70% of the tobacco market in Russia. The work was primarily focused on prevention against violation of the international economic sanctions and the anti-corruption legislation promulgated by the U.S. and UK (FCPA, UKBA).Completion of the tasks set by the Head of Compliance in the course implementation of the compliance strategy in the line with the best practices (COSO Framework, USSC Guidelines, OECD Good Practices, UKBA Guidance). Development, implementation, and annual revision of the Code of Business Conduct and compliance policies (anti-bribery and anti-corruption, U.S./EU sanctions, anti-money laundering, “Know your client”, internal investigations, anti-illicit trade, and anti-trust) in collaboration with the top-tier international law firm. “Transparency international” rated quality of the Code of Conduct and the Anti-Bribery & Anti-Corruption Policy at 82%. Show less

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  M.Video

  Jun 2019 - May 2021

  Head of Compliance Division

  ✔️ Successful improvement of due diligence (KYC) procedure – vetting process became x1,8 faster, more than 500 counterparties was vetted by the end of 2020.✔️ Successful development and implementation of due dilligence (KYC) procedures for new categories of counterparties in the course of transformation of the Group’s business (principals, e-commerce merchants, B2B & B2G purchasers).✔️ Successful development and implementation of the Anti-Corruption Policy from the ground up. Development of the educational course on the Anti-Corruption Policy for all employees of the Group (more than 30,000 participants). Development and implementation of the digital system for whistleblowing and approval of thavels, gifts and intertainments in collaboration with the external IT provider.Here I got my management experience (2-3 subordinates). In addition, I moved from a private company to the public one (listed in the Moscow stock exchange), where compliance policies and procedures were more crucial for the business. The work was primarily focused on prevention against violation of the tax and anti-corrution legislation of Russia. Due to specifics of the business, due dilligence of suppliers was critically important. Show less

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  GDA

  May 2021 - now

  Chief Compliance Officer

  🌐✔️ Successful development and implementation of a compliance program from scratch for the international group of companies Genesis Digital Assets (GDA), one of the leading Bitcoin mining companies in the world. The implementation of the compliance program enabled preparation for a major deal in the U.S. and passing an external audit. The compliance program considers regulatory requirements applicable to GDA's activities in all jurisdictions where it operates: the U.S., UAE, Cyprus, Sweden, Germany, Austria, Switzerland, and Kazakhstan. Additionally, the compliance program takes into account the requirements of the Shareholders' Agreement entered into between the shareholders of GDA.Specifically, the following policies and procedures were successfully implemented:⚙️ Code of Business Conduct: Establishes basic rules for all GDA employees, including rules of conflict of interest resolution, handling of company property, dealing with confidential information, whistleblowing, etc.⚙️ Anti-Money Laundering and Counter-Terrorism Financing Policy (AML/CFT): Establishes procedures for continuous screening of counterparties and transactions, voluntary disclosure to regulatory authorities, whistleblowing, internal investigations, and ongoing training.⚙️ International Economic Sanctions Compliance Policy: Establishes procedures to mitigate the risk of violating the sanctions regime promulgated by the U.S., UAE, EU, Switzerland, and Kazakhstan.⚙️ Anti-Bribery & Anti-Corruption Policy: Establishes procedures necessary for compliance with the U.S. Foreign Corrupt Practices Act (FCPA) and local anti-corruption legislation.🔄 The aforementioned procedures were successfully automated using specialized software. They are continuously tested for further improvement. Company employees receive ongoing training. This ensures that investors can be confident that the Company operates in full compliance with applicable requirements and best market practices. Show less