Rebecca A. Caruso

Rebecca Caruso’s practice focuses on representing individuals, domestic and multi-national corporations, and financial services companies in compliance, enforcement actions, internal investigations, complex litigation, and criminal prosecution matters. She also provides counsel on Bank Secrecy Act and anti-money laundering requirements and compliance. Rebecca has broad experience in the investigation process for both criminal and civil matters and has represented clients under investigation or facing prosecution by the FDIC, NYDFS, DOJ, and other government agencies.

Rebecca has experience in all stages of federal court litigation, including draft complaints, discovery, motions practice, trial, and appeal. Rebecca maintains an active pro bono practice at the trial and appellate stages, especially in the criminal justice arena.

Prior to joining the firm, Ms. Caruso was a federal prosecutor focused on international money laundering investigations, including kleptocracy and national security prosecutions, with experience in both civil and criminal matters. She conducted numerous international financial investigations, litigated complex money laundering and forfeiture issues, and participated in plea and settlement negotiations.

Ms. Caruso recently clerked for the Honorable James P. Jones of the Western District of Virginia (2019–2020) and the Honorable J. Clifford Wallace of the Ninth Circuit (2020–2021).

Experience

Individual manager of multi-national corporation in an investigation brought by DOJ regarding alleged misleading statements in relation to the corporation's emissions testing of its engines.
Non-fungible token (NFT) and crypto company in complying with requests from DOJ relating to the receipt of potentially tainted funds during an investment round.
Commercial entity in conducting internal investigations into the audit of internal controls and misstatements to the external auditor.
Financial institution in complying with subpoena requests from DOJ relating to suspected bank fraud and money laundering by former bank clients.
Financial institution in an investigation, and negotiation of a consent decree, brought by the NYDFS and the FDIC alleging violations of various Bank Secrecy Act (BSA) pillars.

Major national accounting firm in an internal review of auditor independence requirements and compliance.

Federal Housing Finance Agency, the Conservator for Fannie Mae and Freddie Mac, in complex litigation regarding shareholders' challenges to the funding agreement between FHFA and the US Treasury and damages.
Federal Housing Finance Agency, the Conservator of Fannie Mae and Freddie Mac, in Nevada state litigation regarding invalid HOA sales of real property owned by Fannie Mae or Freddie Mac and serviced by various financial institutions.
Foreign individual in cryptocurrency money laundering prosecution by DOJ relating to the operation of an international dark web company.

Johnson v. Prentice. Prepared Supreme Court amicus curiae brief on behalf of Professor John Stinneford from the University of Florida's School of Law, whose scholarly work on the meaning of "unusual" in the Eighth Amendment has had a significant impact on how the Supreme Court thinks about the concept, in which he concluded that solitary confinement is cruel and unusual punishment.
US human rights non-profit on reporting requirements for cash carried during international travel, including US rules and the rules of various foreign nations, as well as how to complete the correct forms.
Cobb v. Georgia Department of Community Supervision. Represented class of deaf and hard of hearing individuals under state supervision, in which the class alleged that the State failed to provide auxiliary aids and services, and reasonable modifications, as required by the ADA and the Rehabilitation Act.
Allums v. United States. Represented inmate in an as-applied Sixth Amendment challenge in a cert petition to the Supreme Court. Asserting that his sentence was not reasonable because the district court considered evidence rejected by the jury and, instead, engaged in judicial factfinding.
Hope v. Harris. Prepared Supreme Court amicus curiae brief on behalf of Professor John Stinneford from the University of Florida's School of Law, whose scholarly work on the meaning of "unusual" in the Eighth Amendment has had a significant impact on how the Supreme Court thinks about the concept, in which he concluded that solitary confinement is cruel and unusual punishment.

Wilson v. McDonough. Represented individual plaintiff before the First Circuit, and in a cert petition before the Supreme Court, alleging that the district court violated the Federal Rules of Civil Procedure in dismissing plaintiff's compliant when it found that the plaintiff "waived" an argument against dismissal by failing to raise a specific argument in opposition to DOJ's motion to dismiss.

Perspectives

May 5, 2023

The Supreme Court Removes Two Obstacles to the Criminal Prosecution of Foreign States in U.S. Courts

Advisory

May 2023

Financial Crimes Enforcement Network Proposes Rule on Access to Beneficial Ownership Information (pdf)

The Banking Law Journal

March 31, 2023

FinCEN Releases First Set of Guidance on the New Beneficial Ownership Information Reporting Requirements

December 21, 2022

FinCEN Issues Proposed Rule on Access to Beneficial Ownership Information

Advisory

December 7, 2022

Takeaways from the OCC’s Revised Civil Money Penalty Manual

Advisory

More

Recognition

Criminal Division's Assistant Attorney General Award for Exceptional Service (2018)

Credentials

Education

J.D., University of Virginia School of Law, 2016
B.A., Political Science with concentrations in International Relations & Public Policy, Minor in History, University of Florida, 2013, cum laude

Admissions

District of Columbia
Virginia
U.S. District Court, District of Columbia
U.S. District Court, Eastern District of Virginia
U.S. District Court, Eastern District of Kentucky
U.S. Court of Appeals for the First Circuit
U.S. Court of Appeals for the Fourth Circuit
U.S. Court of Appeals for the Fifth Circuit

Government & Military Service

Trial Attorney, US Department of Justice, Criminal Division, Money Laundering & Asset Recovery Section
Special Assistant US Attorney, US Attorney's Office for the Eastern District of Virginia
Special Assistant US Attorney, US Attorney's Office for the District of Columbia

Clerkships

U.S. District Court, Western District of Virginia, The Honorable James P. Jones
U.S. Court of Appeals for the Ninth Circuit, The Honorable J. Clifford Wallace

Activities

Member, American Bar Association, Business Law Section
Member, American Bar Association, Criminal Justice Section

Experience

Perspectives

Recognition

Credentials

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