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Bank Secrecy Act/Anti-Money Laundering

We have deep experience advising clients on US and international anti-money laundering and countering the financing of terrorism (AML/CFT) requirements, including the US Bank Secrecy Act (BSA) and the BSA’s implementing regulations. Our team creates, assesses and enhances BSA/AML compliance programs; conducts internal investigations into potential BSA/AML violations and advises on corresponding remedial measures; and vigorously defends financial institutions and other entities in regulatory and enforcement actions alleging BSA/AML violations.

Financial services companies must address constantly evolving illicit finance threats, vulnerabilities and risks, alongside new BSA requirements and developments, and increased government interest in ensuring BSA/AML compliance. We routinely advise financial institutions on the BSA and help clients ensure that their AML/CFT compliance programs fully comply with the BSA and meet or exceed AML/CFT best practices. This includes conducting BSA compliance program reviews; providing training and drafting policies and procedures; analyzing potential customers, products and services for AML/CFT risks; and advising on new legislation, regulations and law enforcement priorities. Our team includes certified anti-money laundering specialists and lawyers that have previously served in the Department of Justice and Department of the Treasury, including the Financial Crimes Enforcement Network (FinCEN).

Our defense work includes representing financial institutions in examination responses and criminal and regulatory BSA/AML investigations and enforcement actions. We have experience representing financial institutions in matters before both state and federal agencies, including the Department of Justice, Department of the Treasury, the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve and the New York State Department of Financial Services (DFS). We also assist financial institutions that must undertake remedial measures or program reviews required by consent orders, settlements or other agreements with government agencies.

As part of our firm’s global footprint, our AML/CFT work goes beyond the BSA, as we routinely advise non-US financial institutions and other entities regarding AML/CFT requirements. This work includes assessing compliance with AML/CFT international standards and best practices, including those set by the Financial Action Task Force (FATF), the Basel Committee on Banking Supervision and the Wolfsberg Group. Our FATF work includes conducting compliance gap analyses to ensure that financial institutions’ AML/CFT programs meet FATF’s standards. We also advise stakeholders, including both government and private sector entities, that are preparing for, undergoing or responding to FATF mutual evaluations. Additionally, we represent non-US financial institutions in regulatory and enforcement matters brought by the UK Financial Conduct Authority, as well as local central banks and regulators.

In partnership with our market-leading Public Policy Practice, we also advise clients regarding pending and contemplated statutory and regulatory developments that potentially impact their BSA/AML/CFT obligations and, when appropriate, can work with those clients to engage decision makers regarding these potential developments, particularly in Washington DC and Brussels.

Relevant Experience

  • Supervised remediation efforts under a DFS consent order for a global financial institution relating to its AML and sanctions compliance programs.
  • Assisted a large African nation, including its financial intelligence unit and AML/CFT regulatory bodies, prepare for, conduct, and respond to its FATF mutual evaluation.
  • Conducted anti-money laundering and sanctions risk assessment for a large multinational financial services company in preparation for its home country FATF mutual evaluation, including advising the company on improvements to its existing financial crime controls. 
  • Advised a regional bank on BSA/AML and sanctions matters related to loans, trade finance and customer due diligence. 
  • Conducted multijurisdictional sanctions and AML/CFT compliance program assessment across the Middle East and Southeast Asia operations of a large international bank.
  • Designed a sanctions and AML compliance program for a multinational telecommunication services provider operating in 16 countries across Asia, the Middle East and Africa. 
  • Conducting multijurisdictional sanctions-, AML/CFT- and FCPA-compliance program assessment for a large financial services holding company and portfolio banks across the Caucasus and Middle East.
  • Conducted large-scale investigations for several international banks in relation to potential breaches of AML and compliance regulations. The investigations were usually conducted in each bank’s jurisdiction and have included a number of banks in the Middle East, Europe and the UK. Following each investigation, we partnered with the banks to remediate their AML/CFT and sanctions compliance programs.
  • Conducted anticorruption-, AML- and sanctions-compliance reviews, risk assessments and due diligence inquiries for numerous Fortune 500 companies. 
  • Advised a publicly traded company on its anti-money laundering compliance program related to its precious metals business