Anti-Money Laundering Compliance and Enforcement Task Force

Greenberg Traurig advises financial institutions, other businesses, and their officers on a wide range of compliance and enforcement matters related to anti-money laundering (AML) laws and regulations, including the U.S. Bank Secrecy Act (BSA) and associated regulations.

We help our clients develop and implement risk-based AML compliance programs, address and respond to AML issues that arise in regulatory examinations, and navigate regulatory and criminal investigations and enforcements actions into alleged money laundering violations.

Capabilities:

• BSA/AML Compliance Assistance. Assist clients in ensuring compliance with BSA/AML requirements, including AML program, BSA record-keeping, and reporting requirements; provide guidance on customer due diligence (CDD), customer identification program (CIP), and enhanced due diligence (EDD) requirements; counsel clients on BSA/AML information sharing.
• Development and Enhancement of Policies and Procedures. Develop and review existing BSA/AML policies and procedures and update them to conform to the latest legal and regulatory developments, enforcement, and money-laundering risks.
• AML Program Training. Provide general, functional, and targeted BSA/AML training to employees, compliance staff, management and directors.
• ‘Best Practices’ Procedures for Non-Financial Firms. Advise non-financial institutions on implementation of AML “best practices,” in recognition that firms not covered by the BSA still face litigation and enforcement risks related to money laundering.
• White Collar Matters & Related Civil Litigation. Represent companies and individuals in money laundering and BSA investigations and enforcement proceedings before the Department of Justice (DOJ), federal functional regulators, CFPB, and state agencies. Counsel clients on issues related to parallel civil-criminal and cross-border investigations. Advise and defend financial institutions and others in the wake of financial misconduct by customers or employees, including allegations related to Ponzi schemes, False Claims Act, mortgage fraud, and others, using a cross-disciplinary approach aimed at helping clients manage and mitigate both government enforcement and private civil litigation risk.
• AML Regulatory & Examinations. Assist clients with BSA/AML examinations, advise on how to address BSA/AML deficiencies identified in examinations, and counsel clients on how to respond to regulators with the goal of minimizing the potential for an enforcement action.
• Regulatory & Enforcement. Provide counsel to domestic and non-U.S. institutions in connection with threatened or actual enforcement proceedings brought by U.S. and non-U.S. government regulators and self-regulatory organizations (SROs), including the Federal Reserve Board (FRB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), Financial Crimes Enforcement Network (FinCEN), Financial Industry Regulatory Authority (FINRA), Securities Exchange Commission (SEC), Commodities Futures Trading Commission (CFTC), the UK Financial Conduct Authority (FCA), the UK Serious Fraud Office (SFO), and the UK National Crime Agency (NCA) and state regulatory agencies including the New York Department of Financial Services (DFS).
• Reporting Suspicious Activity. Counsel financial institutions and businesses on the reporting of suspicious activities in sensitive situations where the institution itself may have civil or criminal exposure.
• Forfeiture Counsel & Defense. Represent clients affected by government seizures, freezing orders, and forfeiture actions under anti-money laundering and related laws.
• Transaction Review & Assistance. Review and analyze BSA/AML risk in business acquisitions. Negotiate, draft, and prepare AML-related representations, warranties, and covenants in transaction documentation.
• Corporate Transparency Act (CTA) Compliance. Advise companies and financial institutions on compliance with new federal beneficial ownership reporting requirements.