Tito Pombra is the founder and president of ACC. He has extensive experience in the global asset management industry, which includes 28 years in the investment company/investment adviser and international compliance areas. His areas of expertise include regulatory exams, outsourced CCO support, annual reviews, mock SEC exams, creating a strong culture of compliance, policies and procedures development, advertising and marketing reviews, NFA/CFTC compliance, and mentoring and training compliance professionals.
Before founding ACC, Tito was president of a compliance consulting firm, where he led the compliance consulting practice to identify and execute new business strategies that resulted in significant new client acquisitions and growth. In addition, he provided proactive compliance advice to clients on Rule 206(4)-7, Rule 38a-1 and private fund compliance programs. He also established policies and procedures, completed annual reviews, and provided mock SEC exams, risk assessments and compliance training for a variety of investment advisers.
From 2005 to 2018, Tito served as chief compliance officer of Matthews International Capital Management, LLC (Matthews Asia) and Matthews International Funds (DBA Matthews Asia Funds). As CCO for Matthews Asia and Matthews Asia Funds, he was responsible for creating and managing the compliance and anti-money laundering programs of the investment company, investment adviser and offshore funds, and assisted with the compliance programs of Matthews Global Investors’ Hong Kong and U.K. registered broker-dealers. In addition, he oversaw the Matthews Asia Funds service provider’s compliance program under Rule 38a-1. During his tenure, Tito was also the AML Officer for the Matthews Asia Funds and MLRO for the Matthews Asia Funds (Luxembourg).
Tito has held various senior compliance and accounting positions at Franklin Templeton Investments and Dreyfus Funds. He graduated from Queens College in 1987 with a bachelor’s in accounting and economics.
Over the past 28 years, Tito has become a thought leader on compliance best practices. He is co-chair of the San Francisco Bay Area CCO Committee and a former member of the board of directors of the National Society of Compliance Professionals (NSCP) and the Investment Company Institute’s (ICI) CCO committee.
In 2008, Tito was named as a Top 20 Rising Star for “Who’s Who” in Upcoming Compliance Professionals by Compliance Reporter magazine. He frequently speaks at industry conferences, including those hosted by NSCP, Investment Company Institute, Investment Adviser Association, IA Watch and Private Equity Institute.
Giselle Casella is vice president and partner at ACC. She has more than 25 years of SEC regulatory compliance experience with registered investment advisers.
Giselle provides outsourced CCO services to RIAs, as well as a full suite of compliance services, including annual compliance reviews, SEC mock audits, compliance testing, regulatory filings and disclosures, code of ethics administration, trade surveillance, policy drafting and updates, email and social media surveillance, compliance training, marketing material review and SEC examination support. She partners with compliance personnel, employees and third-party vendors to develop and oversee compliance programs tailored to each RIA’s unique business. She also currently serves as an adjunct professor at Utica College, where she teaches online graduate courses on compliance.
Giselle began her career in 1999 as an SEC investment adviser examiner. After the SEC, she spent nearly 10 years doing in-house compliance for various large, diversified financial institutions, including AIG, Prudential, UBS, Allianz and Deutsche Bank. During this time, she was responsible for the annual CCO review, oversight of global policies and procedures, preparing regulatory filings and disclosures, trade surveillance, subadvisor due diligence, anti-bribery oversight for gifts and entertainment, as well as political and charitable contributions, employee training and conflicts-of-interest oversight. She also spent nine years as a senior principal consultant for ACA Group, where she provided custom compliance solutions to RIAs.
Giselle has a Bachelor of Business Administration in Finance from Pace University, a Master of Business Administration in Business from Regis University and a Master of Science in Cybersecurity from Utica College. She is a current member of NSCP and former Series 7, 24, and 65 license holder.
Julie Walsh is ACC’s director of SEC and NFA Compliance and a CCO. She has more than 25 years of experience in the investment company/investment adviser and NFA/CFTC compliance areas.
Julie specializes in investment company and investment adviser regulatory compliance programs, as well as programs for commodity pool operators and commodity trading advisers. Her areas of expertise include regulatory exams, annual reviews, mock SEC exams, creating a strong culture of compliance, policies and procedures development, advertising and marketing reviews, and mentoring and training compliance professionals.
Her expertise benefits our clients as she develops compliance programs in an efficient and cost-effective manner. She often conducts gap analyses at the outset of relationships with new clients to capitalize on their existing regulatory/compliance programs (as relevant) and leverage any existing programs and infrastructure. She also engages these efforts in a cross-disciplinary manner — for various regulatory regimes when relevant. Julie is acutely aware that our clients’ core competence is investment management, and she works to judiciously administer programs that are robust and comprehensive and uninstrusive.
Prior to her work with ACC, Julie served as a managing director for more than nine years. During that tenure, she was designated as the outsourced fund CCO for four distinct investment company operations, including a closed-end private equity interval fund, and served as outsourced AMLCO for two open-end investment companies. In carrying out her fund officer delegations, Julie reported directly to each fund’s board of directors. During this time, she also founded the firm’s NFA/CFTC compliance program consultation offerings, and led efforts to train and supervise internal resources in this area.
Earlier in her career, Julie spent 15 years at a Boston-based institutional asset management firm where she served as global adviser CCO, headed the compliance team, and oversaw dozens of open-end investment companies, several hedge funds and private funds, and hundreds of separately managed, dedicated and asset allocation accounts in the institutional space, with assets under management totaling greater than $150 billion.
Julie has a Bachelor of Arts in English and a Master of Education in Secondary Education from Boston College. She is also a member of NSCP, NEBDIAA, SIFMA, ACAMS and the Financial Women’s Association.
Mark De Angelis is a senior compliance consultant and CCO at ACC. During his career, he has held senior compliance positions, including CCO and deputy CCO at Morgan Stanley and T. Rowe Price. He has 22 years of experience in the global asset management industry, most of which was spent as a regulator with FINRA or a compliance officer at an investment adviser or brokerage division of a major financial services organization. More recently, Mark served as an in-house consultant to Belpointe Services, where he used his expertise to assist startup and seasoned investment advisers.
Prior to joining ACC, Mark was a compliance director with a national compliance consulting firm, where he led teams administering compliance programs for investment advisers, registered investment companies and private funds, wealth management advisers, fintech companies and family offices. He also provided proactive compliance management for Rule 206(4)-7 reviews, Rule 38a-1 reviews, private fund compliance programs, as well as service provider monitoring. Mark has led numerous regulatory exams, completed annual reviews, risk assessments and compliance training for variety of investment advisers.
From 1999-2006, Mark served as an analyst and then investigator with FINRA in the advertising regulation and market regulation departments.
During his time as a consultant or in-house compliance officer, Mark has served as CCO for approximately 20 registered investment advisers, broker-dealers and commodity pool operators. As a CCO, he has shown versality in adapting to investment management of clients – whether they’re traditional wealth advisers, mutual funds/ETF sponsors or private fund advisers.
Mark has a Bachelor of Science in Business Administration from the University of Maryland-Towson. and
Russ Lemley is a senior compliance consultant and outsourced CCO at ACC. He has extensive experience in the global asset management industry, which includes more than 32 years in investment company/investment adviser compliance. His areas of expertise include regulatory exams, outsourced CCO support, annual reviews, mock SEC exams, policies and procedures development, exception resolution, compliance training, and mentoring and training of compliance professionals.
From 2004 to 2019, Russ served as chief compliance officer of The American Funds, managed by The Capital Group. He was responsible for administering the compliance policies and procedures of The American Funds, and overseeing the compliance programs of its service providers, including Capital Research and Management Company, American Funds Distributors and American Funds Service Company.
He also held various senior compliance positions at The Capital Group and the U.S. Securities and Exchange Commission.
Over the past 32 years, Russ has become a thought leader on compliance best practices. In 2009, Ignites named him as a Fund Titan. He speaks frequently at industry conferences, including those hosted by the NSCP and the Investment Company Institute (ICI). He is a former member of the ICI CCO Committee and the Curriculum Committee of the NSCP’s Certified Securities Compliance Professional Program.
Russ graduated from the University of California at Irvine with a Bachelor of Arts in Economics with honors.
Kelly Van Deusen is a senior compliance associate at ACC. She began her career in 2015 at a compliance consulting firm in New York City where she helped with business development, compliance recruiting and general compliance work. She then transitioned her career to the technology industry, where she was a project manager for several years in start-up and large, legacy environments. Her focus and expertise was resource management at agile software development consulting firms, where she helped client teams successfully build and scale their products.
Kelly has a Bachelor of Science in Business Economics, and a Bachelor of Arts in Mass Communications from the State University of New York at Oneonta. She holds a Lean Six Sigma Black Belt certification, and has completed the Investment Adviser Core Compliance program. She is a current member of the National Society of Compliance Professionals.
Zoey Armstrong is a senior compliance consultant and outsourced CCO at ACC. She is a seasoned compliance professional with 20+ years of experience in building, implementing and maintaining comprehensive compliance programs, particularly for private funds.
She has a proven track record of developing robust compliance frameworks that ensure adherence to evolving regulatory requirements. Zoey’s solutions-driven approach ensures that her programs are effective, minimally intrusive and aligned with the operational realities of the business, allowing organizations to focus on their core competencies while maintaining a strong culture of compliance.
Prior to joining ACC, Zoey served as chief compliance officer of Siddhi Capital, where she spearheaded the firm’s transition from exempt reporting adviser to registered investment adviser, developing and implementing policies and procedures in compliance with Rule 206(4)-7 of the Investment Advisers Act. She provided strategic guidance on compliance matters, collaborating with various teams to ensure that compliance practices were fully integrated into daily operations. Zoey also played a pivotal role in creating internal compliance resources and training programs to enhance the organization’s regulatory understanding.
Prior to Siddhi Capital, Zoey served as chief compliance officer of Bertram Capital, a private equity firm based in Foster City, Calif. There she led the firm’s transition to a registered investment adviser and implemented a robust, scalable compliance program. Zoey spearheaded initiatives to enhance the firm’s compliance infrastructure and fund governance practices. She also developed comprehensive policies in compliance with Rule 206(4)-7, collaborating with senior management to ensure regulatory adherence aligned with business objectives.
Prior to Bertram Capital, Zoey managed the compliance program at Blum Capital Partners, L.P., a hedge fund based in San Francisco. She oversaw all aspects of compliance, led annual and ongoing reviews, managed complex regulatory filings and designed firm-wide training programs to ensure staff stayed current on regulatory insights. Her early experience as a paralegal at Cooley, LLP and Paul Hastings, LLP in their venture capital and investment management groups provided her with a deep understanding of the legal and compliance intricacies of investment advisers.
Zoey has an NVQ in Business Administration from the City & Guilds of London Institute.
Stephanie Barrett is a compliance consultant at ACC. She specializes in advertising and marketing reviews, registrations, regulatory filings, regulatory exams, policy updates, and social media and email surveillance for SEC/state registered firms.
Prior to joining ACC, Stephanie worked in various roles in the financial services industry, including branch office examiner/auditor for a mid-size, Arizona-based broker-dealer, and most recently as a senior compliance consultant aiding SEC, state and hybrid firms. Within these positions, she has helped firm advisors and CCOs develop and maintain custom professional compliance programs through research and interpretation of applicable rules and regulations.
Stephanie has a Bachelor of Science in Finance and Psychology from Bryant University. She holds FINRA licenses Series 7, 24 and 63. She also has a Master of Science in Clinical Mental Health Counseling. Stephanie splits her time between working as a consultant and a therapist.
