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Money Laundering Watch: 2019 In Review

By Peter D. Hardy, Juliana B. Carter, Brad Gershel, Terence M. Grugan, Gretchen L. Gurstelle, Beth Moskow-Schnoll, Marjorie J. Peerce, Shauna Pierson, Priya Roy, Mary K. Treanor & Jessica C. Watt
January 5, 2020
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Happy New Year! And, happy birthday to Money Laundering Watch, which is entering its fourth year.

Let’s look back.  2019 has been yet another busy year in the world of money laundering and BSA/AML. We are highlighting 12 of our most-read blog posts, which address many of the key issues we’ve examined during the past year — massive bank scandals; beneficial ownership; potential AML reform; virtual currency; cannabis and financial institutions; counter terrorism financing; money laundering prosecutions; and broad policy and social questions implicated by AML concerns.

  • Corporate Transparency Act of 2019 Broadens Beneficial Ownership Reporting
  • New FinCEN Cryptocurrency Guidance Provides Comprehensive Overview of BSA Application to Crypto Businesse
  • Financial Services and the Marijuana Industry:  The U.S. House Mulls Regulatory Reform for Financial Institutions and Cannabis-Related Businesses
  • Massive Dankse Bank Money Laundering Scandal Continues to Unfold
  • Art and Money Laundering
  • Gold and Money Laundering
  • Anti-Terrorism Act Liability Requires More than Mere Failures of Customer Due Diligence
  • D.C. Circuit Rules in Favor of Broad Reach of Patriot Act Subpoenas
  • FinCEN Director’s Remarks Highlight AML Regulatory Reform Efforts
  • What the Basel AML Index Reveals About Global Money Laundering Risks
  • DOJ Indicts Professor and Drug Trafficking Expert for Laundering Proceeds of Venezuelan Corruption Scheme
  • Should the Financial Industry be Detecting Mass Shooters?

We want to thank our many readers around the world who continue to make this blog such a success. The feedback we receive from financial industry professionals, compliance officers, in-house and external lawyers, BSA/AML consultants, government personnel, journalists, and others interested in this field is invaluable, and we hope you will continue to share your perspectives with us.  We pride ourselves on providing in-depth discussions of the important developments in this ever-evolving area.

We also would like to thank the other platforms that host our blog: Digital Currency & Ledger Defense Coalition, Money Laundering Bulletin, and Federal Tax Crimes.

We look forward to continuing to keep you informed in 2020.  If you would like to subscribe to Money Laundering Watch, please click here. To learn more about Ballard Spahr’s Anti-Money Laundering Team, please click here.

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…

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, securities fraud, health care fraud, public corruption, Foreign Corrupt Practices Act violations, and identity theft and data breaches.  He also advises on compliance with the Bank Secrecy Act and Anti-Money Laundering 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.

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Juliana B. Carter

carterj@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…

carterj@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.

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Brad Gershel

gershelb@ballardspahr.com | 646.346.8034 | view full bio

Brad 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…

gershelb@ballardspahr.com | 646.346.8034 | view full bio

Brad 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.

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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…

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.

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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…

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.

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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…

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.

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Marjorie J. Peerce

peercem@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…

peercem@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.

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.

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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…

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.

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Priya Roy

royp@ballardspahr.com | 215.864.8336 | view full bio

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…

royp@ballardspahr.com | 215.864.8336 | view full bio

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.

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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.

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.

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Jessica C. 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…

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. 

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  • Posted in:
    Corporate Compliance, Corporate Finance
  • Blog:
    Money Laundering Watch
  • Organization:
    Ballard Spahr LLP
  • Article: View Original Source

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