Jillana Downing

As an experienced Assistant General Counsel and Chief Compliance Officer with a focus on Registered Investment Advisors (RIA) and venture capital, I bring deep expertise in securities law, investment management, and regulatory compliance. I support the organization in navigating complex legal landscapes, ensuring compliance with SEC regulations, federal and state securities laws, and industry best practices. Most significant achievements in this role are: • Provide strategic legal counsel to senior executives and investment professionals on fund formation, regulatory compliance, securities law, and corporate governance. • Oversee the development and implementation of compliance policies and procedures to ensure adherence to SEC regulations, the Investment Advisers Act, and other federal and state laws. • Conduct regular risk assessments of the firm's investment activities, identifying legal and regulatory risks to ensure compliance with applicable laws. • Lead legal due diligence for investments, including private equity and venture capital transactions, ensuring adherence to both securities regulations and best practices. • Advise on the structuring and offering of private funds, venture funds, and private equity funds, with a focus on investor protection and regulatory compliance. • Manage relationships with outside counsel, regulatory bodies (e.g., SEC), and auditors to ensure that the firm complies with evolving financial services regulations. • Implement and monitor compliance programs covering anti-money laundering (AML), know-your-customer (KYC), data privacy, and anti-corruption, ensuring firm-wide adherence.

Provide regulatory consulting to companies within the financial services industry.

As Senior Executive, I am in charge of implementing essential compliance risk management pillars such as risk assessment, testing, complaints, regulatory change, and training. Concerning critical compliance risk priorities, I collaborate with executive leadership across lines of ddefense. I oversee a financial and banking holding firm that includes subsidiaries for commercial and private banking, broker-dealers, investment advisory services, a trust department, and a venture capital entity. My most significant achievements in this role are: • Created the vision for and led the strategic transformation of the global compliance framework for a top 20 US financial institution, until its collapse in 2023. • Senior executive accountable for the implementation of key compliance risk management pillars, including risk assessment, monitoring and testing, regulatory change, complaints, and training. • Collaborated with executive leadership across the lines of defense on critical compliance risk priorities for the following: a financial and bank holding company, with subsidiaries responsible for commercial and private banking, investment advisory services, broker-dealers, a trust department, and a venture capital entity. • Led the expansion of the Compliance Risk Management department with direct leadership for 76 FTE and 16 contractors. • Built strong relationships with the executive committee and regulatory agencies.

Point of contact for all suspicious activity reports and keep track of all activities reported to Cayman authorities. While communicating with senior management, I create a strong governance framework for overseeing risk associated with the Cayman Islands branch. Key accomplishments include: • Implemented AML systems and controls to evidence compliance with Cayman Island Monetary Authority. • Point of contact for all suspicious activity reports and responsible to file suspicious activities to the relevant Cayman authorities. • Collaborated with senior management to build a strong governance framework to oversee and manage the risk associated with the Cayman Island branch.

Key responsibilities in this role were: Implementation of BSA/AML policy and conducted annual BSA/AML risk assessments while providing excellent training. I interacted with several client-facing teams to identify risks and controls for providing services to high-risk clients. I developed a strong vision for the global BSA/AML program at SVB Financial Group and its subsidiaries. • Led SVB foreign branches, including a Chinese joint venture bank and representative offices across the EU, Asia, and the middle east, in the implementation of BSA/AML regulations. • Approved high-risk clients, such as crypto-focused clients, money service businesses, and other non-bank financial companies.

Identification, analysis and implementation of federal banking legislation and regulations issued by applicable regulatory agencies governing SVB Financial Group and SVB. Provided advice and guidance to the 1st LOD in this role. Noteworthy successes within this role include: • Wrote requests for approval to the SVBFG Board of Directors on Related Party transactions, including policies, etc. • Drafted and filed applications with the Board of Governors of the Federal Reserve Bank of San Francisco and the California Department of Financial Institutions for the following: 3 foreign branches, 1 edge corporation, 1 internal corporate reorganization, and 1 joint venture investment in a foreign bank. • Co-led internal team responsible for analyzing the Dodd-Frank Act and communicating to executive management provisions that would apply to SVB Financial Group, including quarterly reporting to the Governance Committee, a committee of the SVB Financial Group Board of Directors.

• Consult with internal clients and alliance partners for a top 10 acquirer, with primary responsibilities for drafting and reviewing policies and procedures to ensure compliance with applicable regulations and association rules. • Work with various business units to resolve identified issues, and to implement resulting action plans to address deficiencies. • Guide the executive management team on privacy matters.

• Responsible for developing and writing corporate compliance policies, including consumer credit card requirements, privacy, information safeguarding, and data breach requirements, for a top 25 credit card issuers, top 10 acquirers, and the regional retail bank. • Assisted Consumer Bank’s legal counsel with drafting regulatory change notices, writing policies and procedures, and implementing them with the business owners, including senior management. • Appeared in small claims court as needed.

Thesis Topic: “Study of Mentoring Programs in the State of Nebraska”

Major: Criminal Justice Minor: Spanish