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 would like to provide our clients and friends with a resource to discuss trends and developments in enforcement, compliance, and policy. Nearly a dozen federal agencies regulate Anti-Money Laundering (AML) efforts—and penalties for noncompliance range from fines, forfeitures, and indictments to the loss of reputation, stock value, and licenses to participate in the market.

The burden of that scrutiny falls largely to financial institutions, which must develop policies and procedures to identify potential money laundering, fraud, trade embargo violations, tax evasion, and other criminal activity, and report suspicious activity to the government. Affected industries include banks, broker/dealers, casinos, 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 and internet-based providers. They draw on firsthand experience in industry and government to help clients establish and refine AML procedures, advise on customer identification and due diligence, handle government exam preparation and response, conduct internal investigations, respond to enforcement actions, and defend institutions against civil lawsuits by court-appointment 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. They also represent individuals caught up in money laundering and monetary reporting investigations and litigation.

They are on the front lines, helping financial institutions and professionals navigate the world of financial corruption.

Contributors

Peter D. Hardyhardyp@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, securities fraud, public corruption, Foreign Corrupt Practices Act violations, and other financial fraud. He also advises on compliance with the Bank Secrecy Act (BSA) and AML requirements, and leads the firm’s Anti-Money Laundering team. Peter co-chairs the Practising Law Institute’s Anti-Money Laundering program.

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 cases, and as a trial attorney for the Criminal Section of the Department of Justice’s Tax Division in Washington, D.C.

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.

Priya Roy | royp@ballardspahr.com | 215.864.8336 | view full bio

roypPriya focuses her practice on white collar defense, regulatory compliance and complex civil litigation, including the handling of issues involving expert testimony and complicated production and privilege issues pertaining to the BSA.  She counsels institutional clients in BSA/AML regulatory matters and related civil litigations, as well as in matters involving allegations of violations of the False Claims Act and Anti-Kickback Statute, violations of federal and state anti-corruption statutes, securities violations, and other fraud and regulatory offenses. Priya conducts internal investigations and defends companies and individuals facing criminal and civil investigations. She also counsels businesses on improving their compliance programs and best practices. Priya previously clerked for Judges Robert S. Ballou and Michael F. Urbanski of the U.S. District Court for the Western District of Virginia.

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.

Marjorie J. Peercepeercem@ballardspahr.com | 646.346.8039 | view full bio

Margie is a litigator who, in her more than 30 years of practice, has handled matters across the criminal and regulatory spectrum including white collar criminal defense, regulatory matters, and complex civil litigation. Her work includes cases arising from alleged violations of the Internal Revenue Code, the FCPA, the BSA, and a broad range of fraud investigations.  Margie founded Ballard’s Blockchain Techonology and Cryptocurrency team, which she co-leads.

She represents numerous individuals in several AML/BSA investigations by the U.S. Department of Justice and has represented a financial institution in a matter implicating BSA issues. She has handled matters involving Suspicious Activity Reports and Currency Transaction Reports and structuring-related offenses and she has represented individuals accused of money laundering offenses. Margie has also handled a significant number of matters with the SEC, FINRA, and the CFTC.

R. Stephen Stigall | stigalls@ballardspahr.com | 215.864.8369 | view full bio

roypStephen is a trial lawyer whose practice focuses on white collar criminal defense and assisting clients in conducting internal corporate investigations. He served more than 15 years as an Assistant U.S. Attorney in the U.S. Attorney’s Office in Camden, N.J., and was the Attorney-in-Charge of that office for more than five years as well as Deputy Attorney-in-Charge for three years. As an Assistant U.S. Attorney, Stephen led multi-agency government investigations and tried a range of high-profile white collar cases, including many involving money laundering charges. He counsels clients on developing effective and robust corporate compliance programs. His practice also includes defending financial institutions against civil claims alleging failure to adhere to AML and BSA regulations, policies, and procedures.

Melanie J. Vartabedian | vartabedianm@ballardspahr.com | 801.517.6842 | view full bio

Melanie focuses on complex commercial litigation, including securities litigation and litigation involving tort claims predicated on allegations of BSA/AML violations. In addition, Melanie has extensive experience and involvement in government-appointed receiverships. She has prosecuted fraudulent transfer actions on behalf of the receiver in SEC receiverships, and has defended clients sued by various receivers in regards to fraud-related tort claims. She also has litigated cases in state and federal courts across the country, and also has experience representing business clients in arbitrations and government investigations.

Mark S. Kokanovich | kokanovichm@ballardspahr.com | 602.798.5484 | view full bio

Mark is a former federal prosecutor who represents business clients and individuals in regulatory matters, internal investigations, and litigation regarding civil and criminal cases. As an Assistant U.S. Attorney in Arizona for more than seven years, Mark investigated and prosecuted financial crimes, including securities fraud, government contracts, aggravated identity theft, bank fraud, bankruptcy fraud, mail fraud, wire fraud, and international money laundering. He also served as the Suspicious Activity Report (SAR) Coordinator for the Office of the U.S. Attorney in Phoenix, working closely with federal agents to build cases with the assistance of SARs.

Izabella Babchinetskaya | Babchinetskayai@ballardspahr.com | 215.864.8315 | view full bio

Izabella represents clients, including financial institutions, in complex civil litigation, including cases involving allegations of fraud and claims turning on alleged violations of the BSA. Prior to joining Ballard Spahr, Izabella volunteered with the Environmental Crimes Section of the Department of Justice and interned with the Honorable Joel H. Slomsky of the U.S. District Court for the Eastern District of Pennsylvania.

Brad Gershel | gershelb@ballardspahr.com | 646.346.8034 | view full bio

gershel_bradley_1Brad focuses his practice on representing individuals and companies in white-collar criminal and civil matters, including government inquiries and internal investigations. Brad has significant experience in a wide range of enforcement, criminal and regulatory matters, including those relating to fraud, foreign bribery, and public corruption. His experience spans multiple state and federal law enforcement agencies, including the DOJ, FINRA, SEC, and New York County District Attorney’s Office. Additionally, he has represented clients in criminal and regulatory investigations for alleged violations of the False Claims Act and the Foreign Corrupt Practices Act.

Diana M. Joskowicz | joskowiczd@ballardspahr.com |  215.864.8311 | view full bio

Diana focuses her practice on complex commercial litigation, including the defense of financial institutions accused of having enabled alleged fraud schemes perpetrated by former customers against investors, consumers, and others.  When litigating these cases, Diana assists in internal investigations and counsels clients on AML and BSA matters, including complicated issues relating to discovery and expert testimony.

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.

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.

Mary K. Treanor | treanorm@ballardspahr.com | 215.864.8131 | view full bio

Mary focuses her practice on white collar matters and complex commercial litigation. She advises clients on BSA and AML matters, including government and internal investigations. She also counsels financial institutions on SAR filings and confidentiality requirements. Prior to joining Ballard Spahr, Mary worked for a Washington, D.C. law firm, representing clients in market manipulation and failure to supervise enforcement actions brought by the CFTC and FERC. She also advised financial institutions on compliance with the Dodd-Frank Act and corresponding agency regulations.

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, money laundering, and the application of state money services statutes and regulations to virtual currency and related products.