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.
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.
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.
Advised a large national bank in connection with threatened agency enforcement action relating to BSA/AML compliance.
Advised bank with respect to a threatened banking agency enforcement action, resulting in no enforcement action being taken.