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Money Laundering Watch: 2021 Year in Review

By Peter D. Hardy, Richard J. Andreano, Jr., Izabella Babchinetskaya, Siana Danch, Meredith S. Dante, Andrew N. D'Aversa, Brad Gershel, Terence M. Grugan, Kaitlin M. Gurney, Nikki A. Hatza, Henry E. Hockeimer, Jr., John F. Hundley, Diana M. Joskowicz, Brian N. Kearney, Kelly A. Lenahan-Pfahlert, Alexa L. Levy, Laura E. Luisi Gavin, Jacqueline Mabatah, James Mangiaracina, Beth Moskow-Schnoll, Marjorie J. Peerce, Kim Phan, Shauna Pierson & Michael Robotti on January 3, 2022
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Farewell to 2021, and welcome 2022 — which hopefully will be better year for all.  As we do every year, let’s look back — because 2021 was a very busy year in the world of money laundering and BSA/AML compliance, and 2022 is shaping up to be the same.

Indicative of the increased pace and breadth of activity in this space both, our list is bigger this year.  We are highlighting 20 of our most-read blog posts from 2021, which address many of the key issues we’ve examined during the past year: the many permutations of the sprawling AML Act; the Corporate Transparency Act and beneficial ownership reporting; potential AML regulation of the real estate industry; criminal and civil money laundering and BSA enforcement cases; efforts to crack down on domestic and foreign corruption; digital assets and cryptocurrency; data privacy and ransomware; ESG and related social issues; the increasing focus on the potential AML obligations of so-called “gate keepers,” including lawyers; and more:

  • U.S. Passes Historic BSA/AML Legislative Change
  • Proposed Beneficial Ownership Reporting Regulations Under the CTA:  Broad and Complex
  • Real Estate and Money Laundering: FinCEN Issues Advanced Notice of Regulations for the Real Estate Industry
  • FinCEN Identifies AML/CFT “Priorities” For Financial Institutions
  • AML Act Adds Robust New Whistleblower Provisions for Anti-Money Laundering Violations
  • Review, then Reform? AMLA Charts a Path for the Future of SARs and CTRs
  • AML Act Information-Sharing and Privacy and Data Security Concerns
  • ESG, AML Compliance and the Convergence of Social Concerns
  • The OCC Embraces Technology, Proposes Exemption to SAR Requirements and Announces Acceptance of Distributed Ledgers and Stablecoins
  • FinCEN and CFTC Reach Groundbreaking $100 Million AML Settlement with BitMEX
  • Global Developments in AML and Virtual Assets:  FATF Guidance and the Travel Rule, and U.S. Pronouncements on Stablecoins
  • FinCEN Assesses Civil Penalty Against CommunityBank of Texas for AML Program Weaknesses
  • The ENABLERS Act Seeks to Impose BSA/AML Requirements on an Array of “Middlemen” Professionals
  • DOJ Fraud Section 2020 Year in Review: Money Laundering Statute Remains an Overseas Enforcement Tool
  • President Biden Unveils Broad Vision to Crack Down on Foreign and Domestic Corruption
  • FinCEN Issues Notice on Environmental Crimes and Illicit Financial Activity
  • “Real Housewives” Star Indicted for Money Laundering and Fraud
  • FinCEN Solicits Comments on AML Rules for the Antiquities Trade
  • SEC Extracts AML Settlement From Broker-Dealer Based on Alleged Failure to Comply with “Five Essential Elements” of SAR Filings Regarding Cyber Crime
  • U.S. Sentencing Commission Data on Money Laundering and BSA-Related Offenses Reveals:  Courts Often Sentence Below the Guidelines Range

We now move on to 2022.  This year also will be an important and interesting year for BSA/AML and money laundering issues, given the many forthcoming regulations and reports required by the AML Act and the Corporate Transparency Act, which will affect a broad variety of stakeholders.  We look forward to keeping you informed throughout 2022 on these and other developments.

We also 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.

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 comprehensive legal treatise published by Bloomberg…

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 comprehensive legal treatise published by Bloomberg BNA.  Peter 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

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, and public corruption.  He also advises on compliance with the Bank Secrecy Act and Anti-Money Laundering requirements.  Peter handles complex litigation involving allegations of fraud or other misconduct.

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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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…

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.

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Siana Danch

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…

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.

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Andrew N. D'Aversa

daversaa@ballardspahr.com | 215.864.8113 | 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…

daversaa@ballardspahr.com | 215.864.8113 | 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.

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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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Nikki A. Hatza

Nikki Hatza | hatzan@ballardspahr.com |  215.864.8402 | view full bio

Nikki  is a litigator focusing her practice on investigations, commercial litigation, and government affairs. She has experience assisting financial services clients with BSA/AML matters, including in the cryptocurrency space, and conducting internal investigations…

Nikki Hatza | hatzan@ballardspahr.com |  215.864.8402 | view full bio

Nikki  is a litigator focusing her practice on investigations, commercial litigation, and government affairs. She has experience assisting financial services clients with BSA/AML matters, including in the cryptocurrency space, and conducting internal investigations in order to respond to investigations and subpoenas by state and federal regulators. Nikki also has experience in the diversity, equity, and inclusion (DEI) training field and is a member of Ballard Spahr’s DEI Counseling Team, which advises organizations on internal anti-discrimination policies and best practices.

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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…

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.

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Brian N. Kearney

kearneyb@ballardspahr.com | 215.864.8275 | view full bio

Brian assists corporate clients in 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. Prior to law school, Brian…

kearneyb@ballardspahr.com | 215.864.8275 | view full bio

Brian assists corporate clients in 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. Prior to law school, Brian spent a decade as an educator at Saint Joseph’s Preparatory School in Philadelphia.

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Kelly A. Lenahan-Pfahlert

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

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Alexa L. Levy

levya@ballardspahr.com | 215.864.9278 | 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…

levya@ballardspahr.com | 215.864.9278 | 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.

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James Mangiaracina

James Mangiaracina | mangiaracinaj@ballardspahr.com |  215.864.8413 | view full bio

James focuses his practice on commercial litigation matters and white collar defense.  Prior to joining Ballard, he interned for both Magistrate Judge David Strawbridge and Magistrate Judge Timothy R. Rice of the…

James Mangiaracina | mangiaracinaj@ballardspahr.com |  215.864.8413 | view full bio

James focuses his practice on commercial litigation matters and white collar defense.  Prior to joining Ballard, he interned for both Magistrate Judge David Strawbridge and Magistrate Judge Timothy R. Rice of the U.S. District Court for the Eastern District of Pennsylvania.

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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.  She also led the SAR review team for the District of Delaware.

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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.  Shauna was seconded to a major international bank where she advises the Board of Directors on corporate governance issues.

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Michael Robotti

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…

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.

Read more about Michael RobottiEmail
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  • Posted in:
    Criminal
  • Blog:
    Money Laundering Watch
  • Organization:
    Ballard Spahr LLP
  • Article: View Original Source

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