Capabilities
Financial Services

Anti-Money Laundering, USA Patriot Act 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.

Experience

Multi-billion dollar federal savings bank Consent order

Represented client in negotiation of an OCC-issued consent order to address alleged non-compliance with the Bank Secrecy Act and related anti-money laundering regulations.

Large community bank DOJ matter alleging violations of the Bank Secrecy Act

Advised bank in connection with a DOJ matter alleging criminal violations of the Bank Secrecy Act and anti-money laundering laws, and negotiated terms of Deferred Prosecution Agreement.

Large national bank Threatened agency enforcement action

Advised a large national bank in connection with threatened agency enforcement action relating to BSA/AML compliance. 

Multi-billion dollar community bank Threatened banking agency enforcement action

Advised bank with respect to a threatened banking agency enforcement action, resulting in no enforcement action being taken.

Perspectives

Regulatory and Enforcement Trends of 2020 for AML and Sanctions
Arnold & Porter Seminar, New York, NY
Arnold & Porter Discusses Federal Reserve Developments on Confidential Supervisory Information
The CLS Blue Sky Blog
Federal Reserve Developments Relating to Confidential Supervisory Information
Advisory
2019: The Year Ahead in AML and Sanctions Compliance
Arnold & Porter and Protiviti Seminar, New York, NY
Joint Statement on BSA/AML Innovation Provides Clarity and Flexibility
Advisory
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Overview

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