Anti-Money Laundering (AML) Counseling and Investigations

Representative Matters

• 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.