Global and domestic initiatives to prevent and detect money laundering, fraud, and the financing of terrorism are continuing to extend their scope. As these efforts expand, we like to provide our clients and friends with a resource to discuss trends and developments in enforcement, compliance, and policy.
Heavy compliance burdens fall on financial institutions, which must develop policies and procedures to identify potential money laundering, fraud, sanctions violations, tax evasion, and other criminal activity, and report suspicious activity to the government. Affected industries include banks, broker/dealers, casinos, credit unions, cryptocurrency exchanges, residential mortgage lenders, prepaid account providers, and money transmitters. Sometimes scrutiny can fall upon individual executives, owners, and other professionals.
Money Laundering Watch is a blog focused on covering the latest news and developments in the area—and providing the analysis to help you put it all in context. Our bloggers provide insight on compliance and enforcement trends, federal and state actions, regulatory developments, significant cases, and international efforts.
Our bloggers are attorneys who represent financial institutions—from global banks to smaller enterprises. We draw on firsthand experience to help clients establish and refine AML procedures, advise on customer identification and due diligence, handle government exam preparation and response, conduct internal investigations, and respond to enforcement actions. We also defend institutions against civil lawsuits by court-appointed receivers, investors and consumers alleging that the institution harmed the plaintiffs because it failed to prevent a fraud or Ponzi scheme by failing to follow through on its BSA/AML duties. We also represent individuals in money laundering and monetary reporting investigations and litigation.
Contributors
Peter D. Hardy | hardyp@ballardspahr.com | 215.864.8838 | view full bio
Peter is a national thought leader on money laundering, tax fraud, and other financial crime. He is the author of Criminal Tax, Money Laundering, and Bank Secrecy Act Litigation, a well-reviewed and comprehensive legal treatise published by Bloomberg BNA.
He advises corporations and individuals from many industries against allegations of misconduct ranging from money laundering, tax fraud, mortgage fraud and lending law violations, public corruption, Foreign Corrupt Practices Act violations, and other financial fraud. He also advises financial institutions, including banks, money transmitters, cryptocurrency exchanges and non-bank lenders, on BSA/AML compliance. Peter founded the firm’s Anti-Money Laundering team. He co-chairs the Practising Law Institute’s Anti-Money Laundering program, and serves on the Steering Committee for the Cambridge Forum on Sanctions & AML Compliance.
Peter spent more than a decade as a federal prosecutor before entering private practice, serving as an Assistant U.S. Attorney in Philadelphia working on financial crime and money laundering cases, and as a trial attorney for the Criminal Section of the Department of Justice’s Tax Division in Washington, D.C.
Beth Moskow-Schnoll | moskowb@ballardspahr.com | 302.252.4447 | view full bio
Beth is the Managing Partner of the firm’s Delaware office. She is a litigator focused on white collar crime, regulatory enforcement and compliance, and complex civil litigation, with an emphasis on banking and other financial services litigation. She represents major financial institutions, bringing actions against fraudulent debt relief companies, and defending against consumer financial services lawsuits.
Before joining Ballard Spahr, Beth was a federal prosecutor with the U.S. Attorney’s Office for the District of Delaware for more than a decade. She investigated and prosecuted financial fraud, including money laundering, bank and credit card fraud, asset forfeiture, and tax offenses. She also led the SAR review team for the District of Delaware.
Terence M. Grugan | grugant@ballardspahr.com | 215.864.8320 | view full bio
Terence’s practice focuses on representing clients involved in criminal, regulatory, and administrative investigations and litigation, and in civil litigation matters involving the federal securities laws and other allegations of fraudulent business practices. He represents financial institution clients in matters implicating their practices under the BSA and related AML laws, including compliance program advice, internal investigations, regulatory examinations, and related civil litigation.
Michael P. Robotti | robottim@ballardspahr.com | 646.346.8020 | view full bio
As a member of the U.S. Attorney’s Office for the Eastern District of New York for nearly eight years, Mike served as deputy chief of the International Narcotics & Money Laundering section and as senior trial counsel for the Business and Securities Fraud section. Mike was a member of the trial team that prosecuted Joaquín “El Chapo” Guzmán Loera—the leader of the Sinaloa Cartel, the world’s largest drug cartel. Mike handles internal and government investigations, white collar defense and complex litigation. He also advises financial institutions and businesses on their BSA/AML obligations, as well as other compliance requirements, with a focus on issues involving cannabis, cryptocurrency—including scams and theft—and anti-corruption.
Siana Danch | danchs@ballardspahr.com | 215.864.8348 | view full bio
Siana focuses on regulatory compliance and enforcement, white collar defense, internal investigations, tax controversy and complex civil litigation. She advises financial institutions and other businesses on BSA/AML compliance, including issues relating to KYC, beneficial ownership reporting, Suspicious Activity Report filings, Travel Rule compliance, Form 8300 filings, and other BSA/AML reporting and record keeping requirements. Her work in the AML space includes the digital asset industry and related licensing requirements involving federal and state money-transmitter laws. Similarly, Siana represents financial institutions, other businesses and individuals in regards to conducting internal corporate investigations and defending against government criminal and civil investigations and proceedings, including as to allegations of fraud, money laundering, tax violations, and BSA/AML violations. She also represents clients in tax controversy cases, from audit to IRS appeals to litigation.
Andrew N. D’Aversa | daversaa@ballardspahr.com | 215.864.8388 | view full bio
Andrew focuses his practice in matters involving white collar defense/internal investigations and complex civil litigation. His work includes cases involving allegations of money laundering and fraud schemes committed through financial institutions. His work in the BSA/AML sphere also extends to advising clients on state money services statutes and regulations relating to virtual currency and related products. Andrew has served as a judicial law clerk to the Honorable Noah L. Hillman of the U.S. District Court for the District of New jersey, and to the Honorable Anthony J. Sirica for the U.S. Court of Appeals of the Third Circuit.
John Georgievski | georgievskij@ballardspahr.com | 202.777.6073 | view full bio
With his background in licensing, John has experience handling money transmission licensing, mortgage loan licensing, and consumer loans licensing, as well as state-chartered bank licensing, Fintech Sandbox requirements, commercial reverse mortgage licensing, and real estate loans licensing. He also has experience working with mortgage lenders to license MLOs throughout the U.S.
Brian Kearney | kearneyb@ballardspahr.com | 215.864.8265 | view full bio
Brian focuses his practice on white collar criminal and civil matters. His white collar practice includes providing advice on AML and BSA litigation and compliance, including matters involving suspicious activity reports. Brian previously clerked for Judges Renée M. Bumb and Noel L. Hillman of the U.S. District Court for the District of New Jersey.
Kelly A. Lenahan-Pfahlert | lenahanpfahlertk@ballardspahr.com | 215.864.7311 | view full bio
Kelly focuses her practice on white collar defense and complex civil litigation. Kelly has substantial experience in litigating BSA/AML issues on behalf of financial institutions relating to both discovery and liability, assisting with AML-related internal investigations
Alexa L. Levy | levya@ballardspahr.com | 215.864.8278 | view full bio
Alexa focuses her practice on white collar defense and consumer financial services, including the defense of financial institutions accused of having enabled alleged fraud schemes perpetrated by former customers against investors, consumers, and others. Alexa has published on the topic of crimes against humanity and genocide and human trafficking.
Shauna Pierson | piersons@ballardspahr.com | 215.864.8243 | view full bio
Shauna advises financial institution clients on BSA/AML regulatory compliance. She also maintains an active emerging growth practice, which includes counseling start-up companies in the cannabis, hemp and CBD sectors. During law school, Shauna served an internship with the Youth Sentencing and Reentry Project, where she assisted juvenile offenders previously sentenced to life incarceration with reentry planning as they prepared to return to their communities. Shauna currently is seconded to a major international bank where she advises the Board of Directors on corporate governance issues.
Kaley Schafer |schaferk@ballardspahr.com | 202 777.6990 | view full bio
Kaley has a background in regulatory compliance and counsels on BSA/AML requirements, as well as other federal consumer financial regulations. Prior to her role at Ballard Spahr, Kaley served as Director of Regulatory Compliance at the National Association of Federally-Insured Credit Unions, where she led the regulatory compliance team in developing new compliance materials and tools for NAFCU members, including as to BSA/AML issues.