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, and respond to enforcement actions. 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

hardypPeter 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, health care fraud, public corruption, Foreign Corrupt Practices Act (FCPA) violations, and identity theft and data breaches.  He also advises on compliance with the Bank Secrecy Act (BSA) and AML requirements.

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. He was 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

Moskowschnollb

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

Peercem

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.

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.

David L. Axelrod | axelrodd@ballardspahr.com | 215.864.8639 | view full bio

David is a former Supervisory Trial Counsel at the SEC’s Philadelphia Regional Office and a former federal prosecutor. His practice focuses on representing companies and individuals under investigation by government agencies, including the DOJ and SEC, concerning alleged violations of state and federal law, including securities laws and the FCPA, as well as antitrust matters. David also helps FinTech companies, including cryptocurrency (i.e., Bitcoin) issuers, navigate a wide range of regulatory issues and obstacles.

As a federal prosecutor, David prosecuted investigated and prosecuted a number of cases involving money laundering and violations of the BSA.

Stefanie H. Jackman | jackmans@ballardspahr.com | 678.420.9490 | view full bio

Stefanie’s practice focuses on complex litigation and compliance advice relating to all areas of federal and state consumer financial services laws. She has significant experience representing clients in connection with DOJ, SEC, CFPB, FTC, and state attorney general investigations. In addition, Stefanie also regularly performs compliance assessments and mock regulatory examinations for lenders and their service providers to identify potential gaps and areas for improvement within their compliance management systems, including with regard to potential AML issues.

Dennis K. Burke | burked@ballardspahr.com | 602.798.5484 | view full bio

Dennis focuses his practice on white collar crime, internal investigations, commercial litigation, and government relations. He served as U.S. Attorney for the District of Arizona, and has more than 20 years of significant experience in federal and state government. As the U.S. Attorney for the District of Arizona, Dennis oversaw all federal prosecutions in the state and led a range of investigations, including high-profile cases involving white collar crimes, drug trafficking, immigration issues, and fraud.

Juliana B. Cartercarterj@ballardspahr.com | 215.864.8112 | view full bio

Juliana has trial experience with a range of criminal and civil disputes, and assists corporate and individual clients in white collar criminal defense matters. Her white collar practice includes providing advice regarding AML and BSA litigation and compliance, including matters involving suspicious activity reporting, alleged BSA violations by financial institutions, and the crafting of AML and anti-bribery compliance plans. During her judicial clerkship, Juliana handled several white-collar criminal cases, including a high-profile public corruption trial. Prior to joining the firm, she interned in the office of the Philadelphia District Attorney.

Andrew N. D’Aversa | daversaa@ballardspahr.com | 215.864.8113 | view full bio

Andrew focuses his practice on white collar defense. He has experience in matters involving the criminal money laundering statutes and the application of federal and state AML regulations, including as to virtual currency and related products. Andrew maintains an active pro bono practice working with the Pennsylvania Innocence Project.

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.

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.

Gretchen L. Gurstelle | gurstelleg@ballardspahr.com | 612.371.3537 | view full bio

Gretchen guides clients through all stages of federal and state civil, criminal, and regulatory proceedings, from responding to government subpoenas and conducting internal investigations to negotiating with government representatives and litigating any resulting claims or charges. Her practice also focuses on complex civil litigation. Gretchen has represented clients in contract disputes, insurance coverage disputes, and False Claims Act cases. Her white-collar experience includes representing clients facing federal money laundering charges, allegations of federal mail and wire fraud, tax fraud, health care fraud, mortgage fraud, theft, and embezzlement.

Evan W. Krick | kricke@ballardspahr.com | 302.252.4463 | view full bio

Evan Krick

Evan focuses on white collar criminal defense and complex civil litigation, with an emphasis on the banking and health care industries. He has defended clients in federal and state investigations. Evan represented a bank facing money laundering and BSA allegations, a maker of pharmaceutical products investigated for “off-label” marketing, and an individual charged with insider trading.

Before joining Ballard Spahr, Evan was an attorney at the Defenders Association of Philadelphia, where he represented indigent criminal defendants in both felony preliminary hearings and misdemeanor trials.

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

royp

Priya focuses her practice on white collar defense, internal investigations, and complex civil litigation. She counsels clients in AML and BSA matters, as well as matters involving allegations of tax fraud, violations of the False Claims Act and Anti-Kickback Statute, violations of the Food, Drug, and Cosmetics Act, securities violations, and other fraud and regulatory offenses and abusive acts and practices.

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.

Jessica Case Watt | wattj@ballardspahr.com |  302.252.4449 | view full bio

Jessica assists clients with white collar criminal defense, including conducting internal investigations, responding to subpoenas for documents and testimony, cooperating with ongoing investigations, and making presentations to the DOJ prior to indictment. Jessica’s white collar practice includes matters involving advice regarding AML and BSA compliance, as well as defending against alleged violations of the False Claims Act and other fraud and regulatory offenses.

Jessica also practices complex commercial litigation, with experience in cases involving breach of contract, fraud, and disputes related to lending and finance agreements. Her corporate litigation work includes matters of corporate control, corporate governance, statutory and contractual disputes, statutory demands for inspection of corporate books and records, and breach of fiduciary duties.