Anti-Money Laundering (AML)
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The risks for international business associated with increased enforcement of anti-money laundering (AML) laws, including against trade-based money laundering, are growing daily. We help multinational financial institutions and other companies navigate the legal, business, and regulatory AML requirements that arise under the Bank Secrecy Act (BSA) and other applicable Federal and state laws, as well as the many regulators that have a role in enforcing AML requirements. Our team works with clients in their interactions with the Financial Crimes Enforcement Network (FinCEN), the Financial Industry Regulatory Authority (FINRA), the Department of Justice (DOJ), the Office of the Comptroller of the Currency, the Federal Reserve, and state regulators. Where appropriate, we also partner with our colleagues in London and Brussels to address EU AML rules, and EU data privacy rules. 

We routinely work with clients to conduct AML risk assessments, implement appropriate risk-based compliance programs, review the effectiveness of these programs; seek administrative rulings from appropriate regulators; file Suspicious Activity Reports (SARs); draft self-disclosures; provide training on AML laws and regulations as well as internal policies and procedures; provide day-to-day guidance on transaction-specific issues; and respond to government investigations.

We also work with industry groups, including traditional and non-traditional financial institutions, to develop AML best practices. Together our Government Affairs, Corporate, Financial Services, Insurance & Reinsurance, Trade, and White Collar & Regulatory Enforcement groups help trade associations and other organizations address, comment on, and influence laws, policies and enforcement actions by relevant regulatory agencies.

Office of Foreign Assets Control (OFAC)

Parallel to our AML practice, we assist a wide array of multinational and U.S. clients in developing and maintaining risk-based sanctions compliance programs. Where appropriate, we also assist clients in developing export controls policies and procedures. As part of our comprehensive sanctions compliance program, we guide clients on drafting and filing licensing applications, voluntary self-disclosures, requests for advisory opinions, and responses to subpoenas. For our cross-border clients, we work to ensure that compliance policies and procedures address blocking statutes, data privacy concerns, and local sanctions requirements. As active participants in numerous trade associations, we also assist in drafting comments to legislation or proposed rules to ensure clients' concerns are appropriately expressed and, where possible, addressed.

Representative Engagements

  • Represent global financial institution in money laundering investigation involving organized crime and virtual currencies.
  • Represented a well-known broker-dealer as lead counsel in FINRA enforcement investigation regarding allegations of trading unregistered securities without appropriate money-laundering detection capabilities in place. Negotiated a favorable settlement with FINRA.
  • Represent non-U.S. headquartered financial institution in corruption and money laundering investigation initiated by multiple jurisdictions.
  • Providing in-person sanctions and AML training to global financial institution's sanctions compliance officers.
  • Acted as seconded in-house counsel to multiple financial institutions to address AML and sanctions questions.
  • Requested interpretive guidance from FinCEN regarding scope of AML program requirements as they would relate to automotive industry.
  • Worked with counsel in other jurisdictions to provide cross-border information sharing guidance to clients.
  • Provide AML and general regulatory compliance guidance to global trading platform.
  • Represent the Central Bank of Colombia in an action against a financial institution in connection with a $20 million loss in a structured investment vehicle.
  • Represented firms and individuals in several FINRA enforcement matters that involved alleged anti-money laundering violations, specifically involving market making and/or retail customer activity — deemed suspicious by FINRA — in low-priced securities that were sometimes delivered in physical certificate form.
  • Represented Chile's Consejo de Defensa del Estado (Attorney General's Office) seeking discovery from several U.S. and foreign banks regarding former President Augusto Pinochet's money laundering and corruption charges.
  • Represented insurance companies offering covered products in developing and maintaining risk-based AML programs.
  • Represented an industry currently exempt from AML program requirements to develop industry good practices for risk-based voluntary compliance with AML guidelines.
  • Represented a broker-dealer in reviewing and updating AML compliance program.
  • Worked with money transmitter to clarify Bank Secrecy Act regulations requirements and to develop a risk-based compliance program.
  • Assisted broker-dealers with questions regarding the adequacy of customer identification documentation.