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Global Anti-Money Laundering
Contacts
Deborah S. Thoren-Peden
Partner, Los Angeles
T: +1.213.488.7320
deborah.thorenpeden@pillsburylaw.com
William M. Sullivan, Jr.
Partner, Washington, DC
T: +1.202.663.8027
wsullivan@pillsburylaw.com
Aaron R. Hutman
Partner, Washington, DC
T: +1.202.663.8341
aaron.hutman@pillsburylaw.com
Carolina A. Fornos
Partner, New York
T: +1.212.858.1558
carolina.fornos@pillsburylaw.com
Steven Farmer
Partner, London
T: +44.20.7847.9526
steven.farmer@pillsburylaw.com
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From the largest global financial institutions to the internet frontier, Pillsbury lawyers counsel clients in addressing the Anti-Money Laundering (AML) challenges confronting their business. Our deep and experienced team spans the globe and covers the many disciplines crucial to AML matters—financial regulation, compliance, enforcement, investigations and international policy.
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Access our insights: A dedicated Pillsbury task force is closely tracking the evolution of anti-money laundering and corporate transparency legislation, including updated beneficial ownership disclosure requirements. |
In an age of deepening multilateral commitments and increasing enforcement coordination, we help our clients understand the interplay of traditional AML rules, sanctions policies, counterterrorism and counter-proliferation efforts, anti-corruption sensitivities, and ever-changing technology. Our lawyers bring experience from their former roles as government compliance officials, prosecutors and private banking counsel that is critical to understanding how best to advise clients in these sensitive matters.
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Global AML Capacities
U.S. Anti-Money Laundering Law
AML regulation continues to evolve and the definition of “financial institution” continues to expand, with complex legal environments at both the federal and state-level. We advise a diverse range of clients on FinCEN rules and reporting, Bank Secrecy Act (BSA) and USA PATRIOT Act matters, sanctions, emerging online and digital issues, and criminal AML statutes and enforcement. We also advise on New York state financial regulation and enforcement actions.
Federal Financial Regulation
In addition to FinCEN, we work extensively with the Federal Reserve Board, Treasury Department, Comptroller of the Currency, Federal Deposit Insurance Corporation, Office of Thrift Supervision, Securities and Exchange Commission, and Commodity Futures Trading Commission.
Enforcement
Pillsbury attorneys have extensive experience representing financial institutions and their officers and directors in a wide variety of regulatory enforcement actions, internal compliance matters, criminal investigations and related civil litigation. We also advise on U.S. criminal anti-money laundering laws and the Bank Secrecy Act in the context of transactions, funds and financing.
Sanctions
The firm’s leading U.S. and global sanctions practice helps clients to address sanctions issues in the AML context and liaise with Treasury’s Office of Foreign Assets Control (OFAC). U.S. sanctions policies can have a dramatic impact on the activities of financial Institutions (U.S., multinational and non-U.S.) and other businesses. We also advise clients on the overlap of OFAC sanctions and FinCEN “special measures” imposed on jurisdictions and banks.
AML in the Online World
We advise clients at the cutting edge of AML policy in the digital age–FinTech, virtual currency, digital assets, online financial business matters, privacy and data security. This includes addressing AML laws, regulations and compliance obligations including, but not limited to, devising, implementing and maintaining an AML compliance program with required policies, procedures and controls. We also assist clients in conducting risk assessments in the AML context. This includes AML challenges relating to electronic banking, prepaid and gift cards, online payments, e-commerce, and online gambling.
EU and UK Anti-Money Laundering Laws
Throughout the European Union (EU), and particularly in the United Kingdom (UK), AML requirements are becoming increasingly complicated and comprehensive. Our attorneys, including qualified English solicitors, are constantly monitoring AML developments and providing client advice in this area. Attorneys from our London office regularly liaise with the Financial Conduct Authority (FCA) on regulatory, compliance and transactional matters. Our attorneys can provide guidance in the UK on the Proceeds of Crime Act 2002, Terrorism Act 2000, Money Laundering Regulations 2017, Sanctions and Anti-Money Laundering Act 2018, and any amending legislation or regulations. We also monitor European Commission AML Directives and their impact on national legal regimes within the European Union.
Asia and Latin America Anti-Money Laundering Laws
Pillsbury’s Beijing, Hong Kong, Shanghai and Tokyo offices offer experience in financial and AML rules in China and Japan. Our Korea and Myanmar/Burma practice specialties also can offer AML support relating to either of those countries. Finally, we have broad experience in India and an established network of local law firms to address AML and financial regulatory issues.
Our Latin America team has experience throughout the Americas and can advise on AML issues that arise anywhere in the Western Hemisphere. Our attorneys regularly practice in Spanish and Portuguese and have a deep understanding of the culture and sensitivities of this region.
Financial Action Task Force (FATF)
We are long-standing advisors on FATF policy trends and their effects on national AML policies around the world. The FATF has quietly become one of the more influential institutions in the global financial system.. Via its “FATF Recommendations” (previously the “40 Recommendation”) it sets standards for AML, the counter-terrorist-financing and counter-proliferation policy, as well as for how governments cooperate and share information to combat AML, sanctions and anti-corruption challenges. The FATF also assesses compliance by nations with its recommendations and identifies countries that present risks or require counter-measures—both of which can impact banks and businesses active in, or having clients or correspondent accounts from, such jurisdictions.
Addressing AML Challenges
Compliance Planning
We frequently advise our clients on compliance planning to address AML, sanctions and other regulatory challenges. On the AML side, this includes devising, implementing and/or adjusting policies, procedures and controls while developing appropriate risk-based approaches. Our multidisciplinary insights allow us to help clients integrate AML compliance policies and identify issues that may affect particular clients or industries.
Internal Investigations
Our financial, regulatory and white-collar teams have the capacity to plan and execute sensitive investigations in the U.S. and around the world.
Transactions and Due Diligence
We support funds, financial institutions, private equity groups and traditional businesses in addressing AML and related challenges in the context of transactions. These are key deal-risk issues, and we offer clients both legal knowledge and practiced judgment in the transactional context.
White Collar Defense
Should regulators, prosecutors, government investigators or legislative committees probe our clients’ activities, our team has the capacity to advise, prepare and defend our clients.
REPRESENTATIVE EXPERIENCE
- Advising banking industry associations of prominent EU and Caribbean countries on AML, sanctions and relations with the U.S. government.
- Advised prior shareholder of a Swiss banking institution on exposure associated with various DOJ global money laundering investigations, including FIFA, 1MDB, Panama Papers, Petrobras and PDVSA.
- Represented prominent multinational bank in parallel investigations of alleged terrorist financing and money laundering by the U.S. Department of Justice and Office of the Comptroller of the Currency; devised enhanced due diligence and internal controls, including additional know-your-customer rules for correspondent accounts, improved jurisdictional risk classifications, and expanded guidelines for transactions involving physical currency.
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- Helped one of the world’s largest financial institutions prepare AML compliance policies to address foreign currency controls and clients’ efforts to circumvent them.
- Co-represented major international financial institution in a trade sanctions investigation conducted by the Department of Justice, the Manhattan District Attorney’s Office, OFAC and bank regulators.
- Represented money/check processor in connection with a Department of Justice investigation of money laundering and online gambling; no criminal or enforcement action was ultimately pursued.
- Represented number of Swiss banks in a program led by the DOJ and the IRS to identify violations of U.S. tax laws, with a specific focus on U.S.-related accounts held at those banks. After conducting comprehensive internal investigations, we succeeded in negotiating non-prosecution agreements for each of these banks. The Swiss banks voluntarily participated in this program that is officially known as the Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks.
- Provided advice to Middle Eastern free trade zone regarding improvement of its AML and sanctions compliance programs, including a review of best practices among “off-shore” and entity-forming jurisdictions in the wake of the Panama Papers revelations.
- Represented multiple relationship managers in connection with a Panama Papers investigation.
- Advised client on AML, sanctions and other legal issues for opening of new FinTech payments services in Russia and Turkey, and third-party payment and ticket services in the United States.
- Advising multiple companies on state-level money transmitter licensing and compliance issues.
- Represented publicly traded payment processor in a criminal grand jury investigation involving the United States Attorney’s Office in the Southern District of New York regarding the processing of transactions for ‘’e-wallets.”
- Acting as primary outside counsel for a Bitcoin peer-to-peer payment system.
- Advised blockchain companies on federal and state BSA, money transmitter and bit-license requirements.
- Advised multiple token and digital asset offerings on AML, customer due diligence and compliance systems.
- Advised client on the AML and sanctions compliance policies of subsidiary online-payment and prepaid-card businesses.
- Advised private equity investment fund on sanctions, anti-money laundering, bank transfer, anti-corruption and other legal issues.
- Represented officers and directors of a major financial institution in the Pinochet/Equatorial Guinea money laundering investigation; no criminal or enforcement action was ultimately pursued.
- Represented major international financial institution in money laundering investigation involving correspondent bank accounts of offshore bank entity; no criminal or enforcement action was ultimately pursued.
Practice Area Highlights
- Trusted advisor to key jurisdictions—advising the Association of Cyprus Banks on AML issues and an engagement campaign to interact with U.S. regulators about improvements in Cyprus’ AML and sanctions compliance framework; helping multiple Swiss banks to engage with the DOJ and IRS in a major tax compliance initiative; representing the Cayman Islands Ministry of Financial Services and Home Affairs in Washington, DC.
- Offer clients a wealth of enforcement and regulatory experience from former deputy superintendent for compliance at the New York Department of Financial Services, enforcement attorney (Market Abuse Unit) at the U.S. Securities and Exchange Commission, assistant United States attorney at the United States Attorney’s Office, and assistant U.S. attorney, District of Columbia, U.S. Department of Justice.
- Members of the AML team have been recognized for their work in Best Lawyers (published by BL Rankings LLC) in International Trade and Finance Law (2013–2017, 2019) & Criminal Defense: White-Collar (2013–2017, 2019); Chambers USA in International Trade: Export Controls & Economic Sanctions (2012–2019); Chambers UK Data Protection & Information Law (2019); The Legal 500 U.S. in Data Privacy and Protection (2012–2019), International Trade (2012–2019); White-Collar Criminal Defense (2013–2017); The Legal 500 UK in Fintech (2018–2019).