Jacqueline (Jackie) Schaeffer
Overview
Jackie Schaeffer is an associate in Crowell & Moring’s New York office and a member of the firm’s International Trade Group. Jackie focuses her practice on global compliance, regulatory enforcement, investigations, and transactional matters at the intersection of U.S. national security and international trade, including economic sanctions, anti-money laundering (AML), export controls, and the Committee on Foreign Investment in the United States (CFIUS).
Career & Education
- University of California, Los Angeles, B.A., summa cum laude
- Stanford Law School, J.D., 2023
- University of Vienna Law School, L.L.M., 2023
- New York
- Law Clerk for the Honorable Chief Justice of the Supreme Court of the Republic of Rwanda
- Russian
Jacqueline (Jackie)'s Insights
Client Alert | 4 min read | 08.06.25
FinCEN Delays Implementation Date and Reopens AML/CFT Rule for Investment Advisers
Historically, SEC-registered investment advisers have not been subject to comprehensive AML regulation under the Bank Secrecy Act (“BSA”) unless they also qualify as a broker-dealer or other BSA-regulated financial institution. Notwithstanding the absence of a formal requirement to date, many SEC-registered investment advisers have voluntarily adopted AML programs in line with industry expectations and investor demands. However, on August 28, 2024, FinCEN issued its Final Rule, establishing anti-money laundering/countering the financing of terrorism (“AML/CFT”) requirements for Covered Advisers similar to those that apply to broker-dealers. The Final Rule, which was scheduled to take effect on January 1, 2026, required Covered Advisers to maintain written AML programs, perform customer due diligence, file Suspicious Activity Reports (“SARs”) and other reports required of BSA-regulated financial institutions, and retain standard AML records.
Client Alert | 10 min read | 03.27.25
FinCEN Axes Corporate Transparency Act’s Reporting Obligations for U.S. Companies and U.S. Persons
Insights
- |
07.11.23
The Banking Law Journal
OFAC Publishes Guidance on Extended Statute of Limitations
|07.26.24
Crowell & Moring’s International Trade Law
BIS Announces Further Updates to OEE’s Voluntary Self-Disclosure Process for Minor Violations
|01.18.24
Crowell & Moring’s International Trade Law
BIS Expands Export Administration Regulations, Adds 13 Entities to Unverified List
|12.20.23
Crowell & Moring’s International Trade Law
Treasury’s OFAC Announces Magnitsky Designations for Two Former Afghan Government Officials
|12.19.23
Crowell & Moring’s International Trade Law
Jacqueline (Jackie)'s Insights
Client Alert | 4 min read | 08.06.25
FinCEN Delays Implementation Date and Reopens AML/CFT Rule for Investment Advisers
Historically, SEC-registered investment advisers have not been subject to comprehensive AML regulation under the Bank Secrecy Act (“BSA”) unless they also qualify as a broker-dealer or other BSA-regulated financial institution. Notwithstanding the absence of a formal requirement to date, many SEC-registered investment advisers have voluntarily adopted AML programs in line with industry expectations and investor demands. However, on August 28, 2024, FinCEN issued its Final Rule, establishing anti-money laundering/countering the financing of terrorism (“AML/CFT”) requirements for Covered Advisers similar to those that apply to broker-dealers. The Final Rule, which was scheduled to take effect on January 1, 2026, required Covered Advisers to maintain written AML programs, perform customer due diligence, file Suspicious Activity Reports (“SARs”) and other reports required of BSA-regulated financial institutions, and retain standard AML records.
Client Alert | 10 min read | 03.27.25
FinCEN Axes Corporate Transparency Act’s Reporting Obligations for U.S. Companies and U.S. Persons
