Accordo is a full-service, solutions-oriented advisory to the financial services and banking industries. Our approach combines deep subject matter expertise with intelligent, scalable technology. We help our clients achieve their business goals by advising on risk, compliance, operations and anti-fraud programs throughout their life cycle. Accordo is well positioned to assist clients with critical matters, and in the execution of their tactical and strategic objectives.
Robert Masi, Managing Partner & CEO
Mr. Masi is the founding partner of Accordo, having fifteen years of experience in financial services compliance and regulation, and five years’ experience in business management. At Accordo, Mr. Masi oversees compliance program support and management for broker-dealers, investment advisors, and hedge and private equity funds with both domestic and international businesses. In certain instances, Mr. Masi performs the role of Chief Compliance Officer, in which he is responsible for developing or restructuring compliance programs for launch, growth, or expansion, supported by the Accordo team. As CEO, Mr. Masi is responsible for the development and execution of Accordo’s strategies and initiatives, and the management of Accordo’s staff.
Prior to founding Accordo, he was a Senior Consultant with an international consulting firm. From 2004 to 2010, he was an Examiner in the New York City District Office of the Financial Industry Regulatory Authority (FINRA). During his FINRA tenure, Mr. Masi was responsible for conducting routine cycle examinations, branch exams and specialized cause investigations of broker-dealers and registered representatives, which included anti-money laundering and fraud investigations. Prior to working at FINRA, Mr. Masi worked at Sonic Financial Technologies (prior to its acquisition by ConvergEx) in New York, where he supported the Compliance and Operations Departments. Additionally, he worked with the Institutional Sales Group and was the Project Manager responsible for the implementation of trading technology for institutional trading desks.
Mr. Masi holds a Bachelor’s Degree in Finance and Accounting with a minor in Economics from Fordham University’s Gabelli School of Business, and is a Wharton Certified Regulatory Compliance Professional. He is also a member of the National Society of Compliance Professionals, the Association of Certified Anti-Money Laundering Specialists and the Association of Certified Fraud Examiners.
Rao Eswara, Partner & COO
Mr. Eswara is Partner and Chief Operating Officer at Accordo. He has over 22 years of experience assisting broker-dealers, global banks and investment advisors achieve business growth and regulatory compliance. He has a proven track record as a change agent capable of turning around corporations facing regulatory risk, compliance and operational issues. His areas of specialty include corporate strategy, disruptive technologies, Enterprise Risk Management, Anti-Money Laundering, sanctions screening, trade surveillance, sales practices, compliance analytics, fraud detection and prevention, among others.
Over the last decade, he acted as trusted advisor to executive management, senior management committees and boards of directors on a wide range of global regulatory, business and technology trends. Mr. Eswara has also directly interacted with several regulators including FRB, FCA/PRA, U.S. Treasury, FINRA, SEC, OCC, FDIC, OSFI and NBB.
On some of his recent advisory engagements, Mr. Eswara:
- Applied emerging technologies including blockchain, neural networks techniques for KYC and trade finance to bring about business and operational transformation at Deutsche Bank.
- Conducted impact assessment of the DOL Fiduciary Rule and Sales Practices regulation for MFS investment management Advisory and Asset Management businesses; developed adoption roadmap.
- Developed the AML, KYC and Sanctions Screening programs at Capital One and State Street.
- Designed the compliance program including policies, procedures, internal controls, compliance training, compliance monitoring and testing at global banks and broker-dealers.
- Performed compliance and operational risk assessments at various broker-dealers.
- Led internal audit and controls adequacy testing engagements; developed key risk and performance metrics to measure and monitor operational effectiveness using COSO and COBIT frameworks.
- Developed the compliance analytics platform at Morgan Stanley to detect and prevent financial crimes.
- Implemented Dodd Frank Act and Basel III compliance programs at BNY Mellon and Bank of America.
Prior to joining Accordo, Mr. Eswara served as COO within the Morgan Stanley Firm Risk Management Unit and as Managing Director at PricewaterhouseCoopers (PwC) and BNY Mellon leading regulatory compliance initiatives across Capital Markets, Wealth Management and Treasury divisions. Further, he has held key leadership positions at Vanguard, Bear Stearns, UBS and Bank of America.
Mr. Eswara has published several industry whitepapers, has served as a speaker or panelist at a number of industry and customer conferences and has led industry roundtables on risk and compliance topics. He has an M.S in Engineering from Villanova University, an M.S. in Computer Science from Drexel University and an M.B.A in Finance from Columbia University.
Jonathan Bashi, Consultant
Mr. Bashi is a licensed attorney who has spent his entire career working with financial institutions and executives, including broker-dealers, investment advisers, banks and insurance companies. He has worked in both legal and non-legal capacities, including compliance, regulatory, enforcement and litigation, and his experience spans numerous financial products and services, including mortgage-backed securities, CDOs, exchange-traded funds, hedge funds, private-equity funds, retirement plans, annuities and other products.
From 2011 to 2017, Mr. Bashi worked as an attorney with Murphy & McGonigle, P.C., where he regularly counseled clients on legal and compliance obligations under federal securities laws and rules, and in enforcement, review and remedial representations involving FINRA, the SEC and other regulators. From 2008 to 2011, Mr. Bashi worked as an associate attorney with the Wall Street law firm of Fried, Frank, Harris, Shriver & Jacobson LLP. Prior to that, Mr. Bashi worked at AXA Financial, first as an Account Executive counseling clients on qualified and non-qualified retirement plans, including compliance with IRS and Department of Labor rules and regulations, and then marketing variable insurance products to financial advisers in the retail broker-dealer distribution space.
On his representative advisory engagements, Mr. Bashi:
- Reviewed electronic books and records retention policies and procedures for a large broker-dealer and advised on compliance with SEC and CFTC rules governing the Write Once, Read Many (“WORM”) format of electronic record retention.
- Served as an independent monitor for a Fortune-500 bank’s subsidiary broker-dealer to review and test policies and procedures relating to equity research, insider trading and discipline, and recommended remedial changes following the company’s entry into an Acceptance, Waiver and Consent (AWC) letter with FINRA.
- Served as an independent monitor for a registered investment adviser to test and conduct a gap analysis of its escalation policies and procedures following its entry into a settlement with the SEC for violations of the Investment Company Act of 1940 by the company and its affiliated subsidiaries.
- Prepared and filed New Member and Continuing Member Applications and other supporting documents with FINRA for the initial and amended registration of new and existing small, medium and large broker-dealers following their additions of new business lines and changes of control post-merger.
- Prepared and filed Forms ADV and other supporting documents with the SEC for the initial and updated registration of new and existing investment advisers.
- Drafted and revised compliance policies, written supervisory procedures, codes of ethics, business continuity plans and other procedural documents for broker-dealers and investment advisers involved in equities and fixed income trading, clearing, introducing and asset management.
- Negotiated contracts on behalf of broker-dealers and investment advisers entering into third-party service agreements for clearing, margin, electronic access, anti-money laundering, third-party downloader and investment advisory services.
- Represented broker-dealers and investment advisers in enforcement investigations before the SEC, CFTC and FINRA dealing with mortgage bond trading, ISDAFIX manipulation, prime brokerage, and hedge fund and private equity fund management.
Mr. Bashi obtained his B.A. in Economics from the University of Massachusetts, Amherst in 2000, and his law degree from Brooklyn Law School in 2008. He is admitted to practice in New York.
Mr. Palleschi is an experienced compliance risk officer with broad expertise in both retail and institutional investment products, investment advisory, and all aspects of broker-dealer compliance. He brings over twenty-eight years of financial industry compliance experience to Accordo. Mr. Palleschi was formerly Senior Vice President and Deputy Compliance Director at Morgan Stanley, and Director and Senior Control Officer at UBS. In his twenty-five year affiliation with Morgan Stanley, Mr. Palleschi served various functions in the Law and Compliance Departments. From 1994 to 2005, he served as Deputy Director of Compliance responsible for all aspects of product Compliance, including the Trading, Desks and Product departments. Mr. Palleschi is also a FINRA Arbitrator and former member of both the CBOE Advisory and NYSE Disciplinary Panels. He also serves as a litigation consultant providing expert witness testimony.
Mr. Metz is a specialist in Securities and Commodities Compliance and Law, Anti-Money Laundering Compliance and Risk Management. He has expertise in Bitcoins and swaps, and has helped foreign companies register as US broker-dealers. Mr. Metz was Senior Counsel, Chief Compliance and AML Officer at Man Financial from 2006 to 2009. From 1984 to 2006, Mr. Metz worked for various subsidiaries of Prudential Financial as Senior Counsel and/or Compliance Officer, including Chief Compliance Officer, Privacy Officer and AML Officer. He has been a frequent speaker at industry conferences, has held executive positions in industry-wide associations and is accredited with the Association of Certified Anti-Money Laundering Specialists (ACAMS) Certification.
Mr. Ciantro has a seventeen-year career in the financial markets, serving in various roles as a risk manager, trader and salesperson. Prior to Accordo, Mr. Ciantro worked at FINRA from 2007 to 2013, where he served as an integral part of FINRA’s examination staff. During his six-year tenure with FINRA, Mr. Ciantro spent three years as a Principal Examiner, conducting sales practice examinations of FINRA members. He conducted solo examinations of small FINRA members in both New York and London, branch examinations for large clearing firms, and served as lead examiner for examinations of the largest FINRA members. In his last three years with FINRA, Mr. Ciantro served as a Principal Regulatory Coordinator for 35 introducing broker-dealers and 10 clearing firms. Mr. Ciantro holds an MBA and a Masters in Accountancy from Baruch College and FINRA Series 7, 24 and 27 Financial and Operations Principal licenses.
Other members of our consulting team collectively bring over seventy-five years of financial services experience as Risk, Operations, and Compliance Officers and former FINRA and SEC Examination Staff. Their experience includes all aspects of securities and futures brokerage, capital raising, asset and wealth management compliance. Our team is dedicated to applying their skills to provide hands-on, real-time support to our clients.
Ms. Godyla is Project Manager, Recruiting and Marketing Associate and Office Manager at Accordo, where she began as an intern in 2013. Ms. Godyla has played an integral role in building out the firm’s overall marketing strategy, including running campaigns, conducting market research, managing the development of RegTech tools, and supporting internal operations. Prior to Accordo, she worked as a freelancer for the Economic State Development Agency for New York City, focusing on the development of their new website. Ms. Godyla graduated from the University of Rochester with a dual degree in Financial Economics and Russian, and is working towards fluency in both Russian and German.