Anti-Money Laundering, USA Patriot Act, FinCen, and OFAC

We have been active in a variety of USA PATRIOT Act, Bank Secrecy Act, and anti-money laundering matters for our financial services clients, including internal investigations, defense of enforcement actions and civil and criminal litigation, development and documentation of compliance programs, public policy issues, and regulatory counseling. Our anti-money laundering team includes former federal prosecutors as well as former senior officials from the intelligence agencies, the US Department of State, and the US federal banking agencies.

Two of our attorneys regularly assist the Institute for International Bankers in producing its annual BSA/AML/OFAC Training Series for member banks.

Experience Highlights

  • Foreign banking organization (FBO) and its New York office regarding an ongoing multiagency government investigation into the FBO’s compliance with US sanctions regulations and, relatedly, in counseling the FBO on its BSA and OFAC compliance programs and practices.
  • State chartered bank in an internal investigation and related criminal investigations by the US Department of Justice, the Manhattan District Attorney's Office, the New York Attorney General's Office, and the New York State Department of Financial Services.
  • Domestic financial institution in an ongoing multiagency inquiry into potential customer fraud and the institution’s obligations under Bank Secrecy Act requirements regarding money laundering.
  • Mid-size national bank in multiple BSA/AML investigations into potential customer and employee relationships involved in money laundering and terrorist financing.
  • Financial holding company with multiple bank subsidiaries in an investigation and voluntary disclosure to the Treasury Department's Office of Foreign Assets Control relating to potential violations of the Iranian Transactions and Sanctions Regulations.
  • Federal savings bank in an investigation into alleged loan fraud and potential BSA/AML program deficiencies, including navigating enforcement proceedings with the OCC and counseling the bank about a lookback review and various other remedial measures.
  • An Eastern European bank in conducting an investigation regarding certain public reports regarding allegations of money laundering and improper lending activities by the bank.
  • Multinational company in a money laundering and trade sanction investigation into the art market being conducted by the Senate Permanent Subcommittee on Investigations.
  • Major retailer with its country-specific anti-money laundering policies and practices.
  • State chartered commercial bank in connection with investigation of BSA/AML compliance matters, including navigating enforcement proceedings with the OCC and counseling the bank regarding a lookback review.
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