Corporate Compliance & Investigations

Anti-Money Laundering

It’s hard to know if your organization is in compliance when international laws and regulations targeting money laundering and terrorist financing are constantly changing. It takes skilled lawyers who not only stay on top of the shifting regulatory and compliance landscape, but also have the experience necessary to help minimize your risk and the impact of an investigation.

Mintz Levin will evaluate your existing compliance programs and help you strengthen them. We can counsel you on your obligations related to reporting suspicious activity, record keeping, sales and issuance of prepaid products and gift cards, customer identification requirements, acceptance of cash and monetary instruments, and applying regulatory standards to specific financial product designs, agreements, and transactions. We have extensive experience conducting sensitive due diligence and investigations regarding high-risk clients and business segments, helping firms respond to high-stakes law enforcement and regulatory inquiries, and handling enforcement and criminal matters.

Quick Facts

  • Team led by former Chief Anti-Money Laundering and US Sanctions Officer of Fidelity Investments and former federal prosecutor who supervised money laundering cases against organized crime groups
  • Attorneys include former federal prosecutors, former government attorneys, and transactional attorneys with in-depth financial industry experience in the banking, capital markets, derivatives, and payments sectors
  • Regularly advise clients such as banks, broker-dealers, mutual fund complexes, insurance companies, gift card issuers, prepaid access sellers, currency exchangers, money transmitters, money order sellers, and private fund managers

Areas of Focus

  • AML policies, procedures, and systems requirements
  • Suspicious activity investigation and reporting
  • Bank Secrecy Act (BSA) and USA PATRIOT Act examinations and enforcement
  • Conducting and documenting risk assessments in complex organizations
  • Transactions involving high-risk products, services, countries, intermediaries, counterparties, and customers
  • Integration and coordination of AML, anti-corruption, and anti-fraud programs
  • Criminal money laundering matters
  • Counter-Financing of Terrorism (CFT)
  • Trade-based money laundering prevention
  • Know Your Customer (KYC) & Customer Identification Program (CIP) requirements
  • Politically exposed persons (PEPs)
  • Currency Transaction Reports, Form 8300
  • Joint and Travel Rule recordkeeping

Representative Experience

  • Conducted internal investigations for different broker-dealers of trading posing market manipulation and securities fraud risks.
  • Conducted enterprise-wide review of AML and OFAC sanctions compliance programs across large, complex asset management organization with broker-dealer, mutual funds, investment advisers, and private funds.
  • Advised a large money services business on anti-money laundering requirements for new products, prepaid access, gift cards, international money transfers, and money order sales.
  • Advised a start-up money services business on transactions involving Mexican currency and financial institutions.
  • Helped various broker-dealers respond to AML inquiries from FINRA.
  • Developed methodologies, algorithms, and supporting documentation for a large depository institution to assess money laundering and terrorist financing risks for product and service offerings and foreign financial institution relationships.
  • Advised a large mutual fund transfer agent regarding payment systems requirements for transmittals of funds and Form 8300 requirements for 529 plans.
  • Advised a medical device manufacturer on a federal investigation into potential trade-based money laundering and black market peso transactions by Colombian distributor.
  • Engaged by FINRA to serve as AML expert in enforcement actions.
  • Oversaw targeted AML and anti-corruption due diligence on Russian prospective investors in US private placement.

Clients We Serve

  • Banks and trust companies
  • Broker-dealers
  • Mutual fund complexes
  • Money service businesses
  • Insurance companies
  • Private fund managers