EMPLOYMENT HISTORY

1999 - Present

Attorney, Private Practice

Representation and counsel to refiners and users of precious metals regarding regulatory, corporate and environmental compliance.

_________________________

2004 - Present

Compliance Officer (2004-2008) and Compliance Monitor (2008 - Present), Metalor Technologies USA Corp.

Developed and directed Anti-Money Laundering Compliance Program of major international gold refiner. Ongoing monitoring of implementation.

_________________________

1996 - 1999

General Counsel, Secretary and Director of Handy & Harman Refining Group, Inc.

Representation and counsel to refiner of gold and silver with facilities in four states and Singapore, 210 employees, US$1.1 billion annual metal value

Advised re contracts, human relations, labor, finance; oversaw environmental compliance; drafted corporate policy; assisted in business development.

_________________________

1986 - 1996

Environmental Counsel, Handy & Harman

Representation and counsel regarding environmental regulatory compliance at precious metal refiner and specialty metal manufacturer with multiple plants and subsidiaries, 2000+ employees, and US$500 million revenue.

Responsibilities included incident response, site remediation, oversight of litigation.

_________________________

1976 - 1986

Carmody & Torrance, Partner 1983-86/Associate 1976-83

General practice law firm in Connecticut with 35 attorneys (1986); trial and appellate litigation; labor, employment; environment.

_________________________

GOVERNMENT AFFAIRS and INDUSTRY ASSOCIATIONS

Environmental and Regulatory Affairs Committee, International Precious Metals Institute (IPMI)

Chairman of Committee (1988 to present) representing secondary precious metal refiners. Write and present industry position papers to government departments, agencies and private groups; write industry comments upon proposed U.S. regulations; chair meetings, workshops, conference sessions and ad hoc group presentations. Achieved sound working relationship between industry and U.S. EPA; exemption from incompatible regulation of boilers and industrial furnaces; non-waste classification of precious metal-bearing electronic scrap.

Financial Affairs Task Force

Representative of precious metals industry (2007-2008) and lead writer of Guidance on Risk-Based AML for Dealers in Precious Metals and Dealers in Precious Stones.

Basel Convention on the Control of Transboundary Movement of Hazardous Wastes

Industry Representative (1992 - present). Represent and speak at Basel Convention meetings; write and present meeting reports to industry organizations; write position papers; represent industry positions in meetings with United States government delegation. Participate actively in working groups of Mobile Phone Partnership Initiative and Partnership on Action for Computing Equipment, Co-Chair working group on material recovery.

U.S. Department of Commerce Industry Trade Advisory Committee on Nonferrous Metals and Building Materials (ITAC 9)

Member of Committee (2002 - present). Present industry position to U.S. Department of Commerce and the Office of the U.S. Trade Representative in development of U.S. trade policy and negotiations. Represent Committee in Doha Round WTO meetings and conferences (WTO Ministerial Conferences: Geneva 2009, Hong Kong 2005, and Cancun 2003).

U.S. Treasury Bank Secrecy Act Advisory Committee

Represent IPMI (2007-present) in Industry Position for Dealers in Precious Metals, Stones and Jewels. Advise Treasury and share AML positions among financial institution industry advisors.

_________________________

EDUCATION

• J.D., Yale Law School, 1976
• B.A., Yale University, 1972

_________________________

BAR ADMISSIONS

• Connecticut, state courts
• United States District Court, District of Connecticut
• United States Court of Appeals, Second Circuit
• United States Supreme Court

_________________________

SPEAKING ENGAGEMENTS

• "Chloroplatinate Toxicity: Use and Misunderstanding of Merget" International Precious Metals Institute, Annual Conference, 15 June 2010, Tucson, Arizona, USA
• "Social Responsibility and Gold" International Precious Metals Institute, Annual Conference, 15 June 2009, Orlando, Florida, USA
• "Communication of AML Suspicious Activuty" Silver Users Association and International Precious Metals Institute, Annual Conference, 16 June 2009, Orlando, Florida, USA
• "Risk-Based AML for Dealers in Precious Metals" Gafisud Seminar on Non-Financial Businesses and Professions, 5 May 2009, Lima, Peru
• "International Regulation of Precious Metals" International Precious Metals Institute, Annual Conference, 8 June 2008, Phoenix, Arizona, USA
• "Precious Metal Recovery from Automotive Catalytic Converters" World Recycling Forum - Shanghai '07, 14 November 2007, Shanghai, China
• "Money Laundering and Precious Metals" World Bank's Program for Leadership in Financial Integrity, 25 October 2007, Washington, DC, USA
• "Regulation of Secondary Precious Metal Operations" Society for Mining, Metallurgy, and Exploration, Precious Metals Processing Symposium, 6 October 2007, Tucson, Arizona, USA
• "New Regulations for Precious Metals" International Precious Metals Institute, Annual Conference, 12 June 2007, Miami, Florida, USA
• "Money Laundering and Precious Metals" Columbia University, School of International & Public Affairs, 3 April 2007, New York, New York, USA
• "Practical Lessons in AML Implementation," International Precious Metals Institute, Annual Conference, 11 June 2006, Las Vegas, Nevada, USA
• "Money Laundering and Precious Metals: Implementing an AML Program," Columbia University, School of International & Public Affairs, 18 April 2006, New York, New York, USA
• "Anti-Money Laundering for Dealers in Precious Metals," International Precious Metals Institute, New York Metro Chapter, 20 September 2005, New York, New York, USA
• "AML for Precious Metals: Beyond the Final Rule," International Precious Metals Institute, Annual Conference, 12 June 2005, Orlando, Florida, USA
• "Metal Recovery from Mobile Phones," U.S. EPA National Electronics Meeting, 28 February 2005, Washington, DC, USA
• "Money Laundering and Precious Metals: Implementing an AML Program," Columbia University, School of International & Public Affairs, 22 February 2005, New York, New York, USA
• "Global Recycling Guidelines: The Mobile Phone Example," Workshop: Where Are WEEE Going?, 7 October 2004, Antwerp, Belgium
• "Anti-Money Laundering for Dealers in Precious Metals," International Precious Metals Institute, New York Metro Chapter, 22 September 2004, New York, New York, USA
• "Anti-Money Laundering for Dealers in Precious Metals," International Precious Metals Institute, Mid-States Chapter, 14 August 2004, Chicago, Illinois, USA
• "Resource Recycling and Basel Convention Partnerships," 2004 China-Canada Resource Recycling Summit (E-waste Managemet, Policy, Regulation and Modern Technology, 28 July 2004, Beijing, China
• "Living With the Final AML Rule," International Precious Metals Institute, Annual Conference, 16 June 2004, Phoenix, Arizona, USA
• "Basel Convention Initiatives re Electronic Scrap," IEEE / IAER Summit on Electronics Recycling, 12 May 2004, Phoenix, Arizona, USA
• "Anti-Money Laundering Seminar for Dealers in Precious Metals, Stones or Jewels," International Precious Metals Institute, New England Chapter, 21 January 2004, Warwick, Rhode Island, USA
• "Money Laundering and Dealers in Precious Metals," International Precious Metals Institute, Metro New York Chapter, 24 September 2003, New York, New York, USA
• "Risk Assessment: Processing Used Electronic Equipment," U.S. EPA 2003 RCRA National Meeting, 14 August 2003, Washington, DC, USA
• "Something Old, Something New: Money Laundering and Precious Metals," International Precious Metals Institute, Annual Conference, 16 June 2003, San Juan, Puerto Rico
• ”Money Laundering and Precious Metals: New Regulations,” International Precious Metals Institute, New England Chapter, 15 January 2003, Providence, Rhode Island, USA
• ”Analysis of Environmental and Human Health Risk of Electronic Scrap Recycling,” Basel Convention, Asia-Pacific Regional Center, 20 November 2002, Tianjin, China
• "Regulatory Developments Impacting Silver," Silver Users Association, 30 October 2002, Washington, DC, USA
• ”Export of Electronics Waste: Addressing the Harm,” National Recycling Coalition, 9 September 2002, Austin, Texas, USA
• "The Good, the Bad, and the Ugly: Getting a Fair Deal in Precious Metal Refining,” International Precious Metals Institute, 16 June 2002, Miami Beach, Florida, USA
• ”An Industry View on Environmentally Sound Management,” Organization for Economic Cooperation and Management, Working Group on Waste Prevention and Recycling, 22 March 2002, Washington, DC, USA

_________________________

PAPERS

• "Chloroplatinate Toxicity: Use and Misunderstanding of Merget", Proceedings, International Precious Metals Institute, 2010
• "Communication of AML Suspicion by Dealers in Precious Metals: Defamation and Defenses ", Proceedings, International Precious Metals Institute, 2009
• "Practical Lessons in AML Implementation", Proceedings, International Precious Metals Institute, 2006
• "AML for Precious Metals - Beyond the Final Rule", Proceedings, International Precious Metals Institute, 2005
• "Risk Assessment: Processing Used Electronic Equipment", Proceedings, U.S. EPA 2003 RCRA National Meeting, 2003
• "Something Old, Something New: Money Laundering and Precious Metals", Proceedings, International Precious Metals Institute, 2003
• "The Good, the Bad, and the Ugly: Getting a Fair Deal in Precious Metal Refining", Proceedings, International Precious Metals Institute, 2002
• "Elements of a Contract for Precious Metal Refining", Proceedings, International Precious Metals Institute, 2001
• "The IPMI Petition on Prepared Sweeps," Proceedings, International Precious Metals Institute, 2000
• "An International Superfund – The Liability Protocol of the Basel Convention," Proceedings, International Precious Metals Institute, 1999
• "The U.S. Regulatory Classification of Prepared Sweeps," Proceedings, International Precious Metals Institute, 1998
• "Push Comes to Shove at the Basel Convention," Proceedings, International Precious Metals Institute, 1997
• "RCRA Classification of Circuit Boards," International Precious Metals Institute, 1997
• "The Basel Convention and Trade," Global Environment and Trade Study, 1996
• "The Basel Convention and Trade in Scrap Metal," Recycling Today, 1995
• "Environmentally Sound Management of Electronic Scrap," Proceedings, Institute of Electrical and Electronics Engineers, Symposium on Electronics and Environment, 1995 and Proceedings, International Precious Metals Institute, 1995
• "Superfund Liability of Precious Metal Refinery Customers," Proceedings, International Precious Metals Institute, 1994
• "Trade, Environment and Government Control: The Basel Convention as Paradigm," Proceedings, International Precious Metals Institute, 1994
• "A proposal for Regulatory Control of Secondary Precious Metals," Proceedings, International Precious Metals Institute, 1993
• "Jaws 2: The Continuing Future of International Trade in Secondary Precious Metals," Proceedings, International Precious Metals Institute, 1992
• "The Basel Convention and the Future of International Trade in Secondary Precious Metals," Proceedings, International Precious Metals Institute, 1991
• "United States Environmental Classification of Precious Metal Refinery Intermediate Products," Proceedings, International Precious Metals Institute, 1989