Risk advisory from someone who has built and run the functions.
Semper Clarus Risk Advisors is the practice of Rick Hamilton. Twenty‑five years at National City and PNC building risk functions and the governance beside them, including AML detection on machine learning.
Fractional and interim risk leadership
AML, capital and balance‑sheet management, or enterprise risk. Chief risk officer or equivalent. Leading the team in place, recruiting one that is not, or steadying a program.
AML program assessment and roadmap
Where the program stands and where it must go: vendor and program fit, what it must prove to an examiner, and where AI earns its place. Delivered as a written assessment and a plan.
Board and executive advisory
What a program can actually do, what a technology decision commits the firm to, and what will hold up when an examiner asks. Standing counsel, or a single session.
Approach
How the work is done.
A problem presented as a technology problem often is not one. Alert volumes nobody can work through usually point at unclear risk appetite, thin standards, or a team without the mandate to enforce them, as much as at the platform producing them.
An engagement therefore starts with what the program is being asked to do, and by whom: the board, the regulator, the business. Only then does it turn to whether the people, the standards, the models, and the reporting are equal to it. Most of what follows is ordinary program management. Getting the right people in the right roles, setting standards that hold, and putting the output in front of whoever has to act on it.
Models are part of that, and Rick has built them. They are rarely what decides whether a program survives review. The same sequence applied to financial crime, to economic capital, and to interest‑rate risk, which is why the practice can cover an assessment and an interim leadership seat without either being a stretch.
From advice to execution, the work stands up to board, audit, and regulatory scrutiny.
Affiliations
Firms the practice works with.
A partnership of independent C‑level executives doing transformational consulting and interim leadership for private‑equity‑backed middle‑market companies. The institutional vehicle behind the fractional and interim work. Profile
Federated learning for financial crime detection. Client strategy and adoption, external leadership and partnerships, market intelligence, and product direction. A direct continuation of the cross‑bank federated learning work led at PNC.
An AML technology strategy assessment, defining near‑ and medium‑term technology needs for financial intelligence units and banks against requirements that keep changing.
Speaking and writing
Selected talks.
- Jun 2026 · GFMI Building a Responsible AI Playbook for Risk Teams
- Apr 2026 · Georgetown The Future of Financial Integrity: Technology & Risk Identification
- Oct 2025 · Fidelity / Saifr Myth Busters: six thoughts that might be holding back innovation in AML/KYC compliance
- Aug 2024 · Ai4 How AI Is Helping To Take The Risk Out Of Risk ManagementRecording
- Aug 2023 · Ai4 The AI/ML Assist: Anti‑Money Laundering and Countering the Financing of Terrorism
Published with Consilient, in American Banker, and in PECB Insights. Longer pieces go out through the newsletter, and the full record of talks and articles is on Rick's personal site.