Bank Secrecy Act/Anti-Money Laundering & Sanctions
Practice
Compliance with Bank Secrecy Act/anti-money-laundering, counter-terrorism financing,
and sanctions laws is a top priority for financial regulators and law enforcement, as
evidenced by an ongoing drumbeat of significant enforcement actions. Failure to comply
with this increasingly complicated regime of laws and regulations — and to meet tough
regulatory expectations in doing so — can result in fines, indictments, and restrictions on
corporate operations and transactions, as well as a loss of public confidence, reputation,
and shareholder value.
Buckley’s core strength is in financial services regulation, and our team’s intimate
knowledge of banks, money services businesses (MSBs), virtual currency businesses,
and other participants in the payments industry, provides us valuable insights into each
client’s specific needs and how to meet them.
Our BSA/AML team includes the former deputy chief counsel of the Office of the
Comptroller of the Currency, as well as former banking enforcement and securities
regulators, federal prosecutors, and in-house compliance officers and bank counsel.
We have extensive experience in internal investigations, enforcement actions, and
investigations and regulatory examinations by the Department of Justice, state
prosecutors, the Financial Crimes Enforcement Network, the Office of Foreign Assets
Control, the Office of the Comptroller of the Currency, the Federal Reserve Board, the
Securities and Exchange Commission, the New York State Department of Financial
Services, and all other federal and state bank and nonbank financial regulatory
authorities.
Our deep experience in all aspects of BSA/AML sanctions enforcement and compliance,
includes:
Developing prospective measures such as AML and sanctions-compliance
programs
Identifying, evaluating. and remediating AML and sanctions-compliance
challenges
Conducting internal investigations to identify the causes of challenges and
lookback reviews to identify appropriate scale
buckleyfirm.com
Leading government disclosures and interactions, including enforcement-
action defense and settlement negotiations
Assisting clients in complying with requirements typically contained in
enforcement actions and settlements
In addition to AML and sanctions compliance and enforcement services, we provide
transaction-related due diligence and risk counseling for mergers and acquisitions,
private equity investments, and credit transactions. The team also provides BSA/AML
training for boards of directors, executive management, and professional staff.
Noteworthy work by our team includes:
Representing numerous large, international banks in multiagency regulatory
and criminal investigations into compliance with sanctions laws, resulting in
deferred prosecution agreements, civil money penalties, cease and desist
orders, and independent monitorships; and assisting many of those same
institutions in complying with a multitude of sanctions requirements imposed
by multiagency settlements
Representing global financial institutions in front of the DOJ, state attorneys
general, and federal and state banking regulators in significant BSA/AML
investigations, where multi-agency enforcement actions and criminal liability
are at stake
Assisting the U.S. branch of a foreign global systemically important bank
with compliance and reporting requirements of an OCC cease and desist
order
Responding to and resolving numerous OFAC subpoenas initiating civil
investigations of compliance with sanctions laws, resulting in cautionary
letters or no action being taken by OFAC
Representing independent board committees of financial institutions charged
with investigating deficiencies in their BSA/AML programs
Developing AML and sanctions compliance programs for a wide range of
financial and non-financial institutions, from GSIBs to small community
banks, MSBs, virtual currency businesses, residential mortgage lenders, and
U.S. exporters
Representing clients in front of OFAC, including identifying and investigating
numerous apparent violations of sanctions laws and drafting voluntary
buckleyfirm.com
disclosures to OFAC; obtaining OFAC licenses on behalf of our clients; and
evaluating the application of U.S. sanctions laws to numerous foreign
businesses, individuals, and financial institutions
Evaluating numerous business arrangements, including prepaid card
arrangements and issuance of virtual tokens, to identify MSB registration
requirements
Representing witnesses before numerous congressional committees,
including the U.S. Committee on Homeland Security and Government
Affairs’ Permanent Subcommittee on Investigations, the U.S. House
Financial Services Committee, and the U.S. House Committee on Oversight
and Government Reform.
News & Blogs
OFAC issues amended Ukraine-/Russia-related FAQs
OFAC sanctions persons connected to Nicaragua President Ortega; amends
Nicaragua sanctions regulations and Ukraine-related general licenses
UAE manufacturer settles OFAC, DOJ charges for apparent North Korean
sanctions violations
Terrorist Financing Targeting Center designates ISIS-affiliated financial
facilitators and money services businesses
OFAC issues sanctions for supporting Russian financier
OFAC issues amended Venezuela-related general license and FAQ
FinCEN updates FATF-identified jurisdictions with AML/CFT deficiencies
OFAC sanctions persons for human rights violations in China’s Xinjiang
region
OFAC settles with global e-commerce, digital service provider over multiple
sanctions violations
OFAC revokes Venezuela-related general license
Partners
buckleyfirm.com
Daniel R. Alonso Kari K. Hall Benjamin B. Klubes
David S. Krakoff Jeffrey P. Naimon James T. Parkinson
Lauren R. Randell Christopher F. Regan Thomas A. Sporkin
buckleyfirm.com
Daniel P. Stipano
Counsel
Benjamin W. Hutten
buckleyfirm.com
Powered by TCPDF (www.tcpdf.org)
