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 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.

Firm/Organization: Ballard Spahr LLP

Blogs: Consumer Finance Monitor, CyberAdviser, Money Laundering Watch

Latest Articles

Money Laundering Watch

What the Basel AML Index Reveals About Global Money Laundering Risks

By Peter D. Hardy

September 3, 2019

Today we are very pleased to welcome guest bloggers Gretta Fenner and Dr. Kateryna Boguslavska of the Basel Institute on Governance (“Basel Institute”). The Basel Institute recently issued its Basel AML Index for 2019. As they explain below, this data-rich and fascinating Index, on which we blogged last year, is one of several online tools developed by the Basel Institute to help both public- and private-sector practitioners tackle financial crime. The Index is a…

Money Laundering Watch

FinCEN Announces New “Global Investigations Division” Focused on Foreign Money Laundering Threats

By Peter D. Hardy

August 28, 2019

The Financial Crimes Enforcement Network (FinCEN) issued a press release today, entitled “New FinCEN Division Focuses on Identifying Primary Foreign Money Laundering Threats.” The announcement states that this new Division will focus on topics about which we have blogged repeatedly: Section 311 of the USA Patriot Act and threats posed to the financial system by narcotics trafficking and the financing of terrorism. Pursuant to Section 311, FinCEN is authorized to designate foreign financial…

Money Laundering Watch

FinCEN Director Blanco Addresses AML Compliance and Casinos

By Peter D. Hardy

August 14, 2019

FinCEN Director Kenneth A. Blanco delivered prepared remarks on August 13 at the 12th Annual Las Vegas Anti-Money Laundering Conference. We previously have blogged repeatedly on the anti-money laundering (“AML”) and Bank Secrecy Act (“BSA”) challenges facing the gaming industry. This post will discuss Director Blanco’s comments at a high level only, consistent with the generality of his prepared speech.…

Money Laundering Watch

Former Bank General Counsel Enters into Consent Order Over Alleged AML Obstruction

By Peter D. Hardy

July 24, 2019

The Office of the Comptroller of Currency (“OCC”) issued an extraordinary announcement regarding the decision of a former bank general counsel – Daniel Weiss, formerly employed by Rabobank, N.A. – to enter into a Consent Order in which Mr. Weiss agreed to be barred from the banking industry and pay a $50,000 fine. The Consent Order is relatively generic; the Notice of Charges issued by the OCC which lead up to the Consent Order is…

Money Laundering Watch

OFAC’s Revised Reporting Rules Create New Compliance Requirements for All U.S. Persons

By Peter D. Hardy

July 16, 2019

Foreign Banks Reliant on U.S. Correspondent Services Should Take Note of New Rules We are pleased to present this guest blog by Hdeel Abdelhady, who is a Washington, D.C.-based attorney and Principal at MassPoint Legal and Strategy Advisory PLLC, her boutique law and strategy firm. Ms. Abdelhady focuses on regulatory compliance and transactional matters, including cross-border trade and finance transactions and regulation. As Ms. Abdelhady discusses, the Office of Foreign Assets Control (…

Money Laundering Watch

Senate Committee Hears from OCC, FinCEN and FBI on Risks Posed by Anonymous Corporate Structures

By Beth Moskow-Schnoll, Priya Roy & Peter D. Hardy

May 23, 2019

Testimony Supports Bill Requiring States to Collect Beneficial Ownership Information at Entity Formation As we have blogged, the proposed Corporate Transparency Act of 2019 (the “Act”) seeks to ensure that persons who form legal entities in the U.S. disclose the beneficial owners of those entities. Specifically, the Act would amend the Bank Secrecy Act (“BSA”) to compel the Secretary of Treasury to set minimum standards for state incorporation practices. Thus, applicants forming a corporation…

Money Laundering Watch

FinCEN Again Extends Real Estate GTOs

By Priya Roy & Peter D. Hardy

May 16, 2019

The Financial Crimes Enforcement Network (“FinCEN”) has, once again, extended its Geographic Targeting Order (“GTO”) requiring U.S. title insurance companies to identify the natural persons behind legal entities used in purchases of residential real estate performed without a bank loan or similar form of external financing. Again, the monetary threshold remains at $300,000, and purchases involving virtual currency are within the reach of the GTO, as well as purchases involving “fiat” currency, wires, personal or business checks, cashier’s…

Money Laundering Watch

Financial Services and the Cannabis Industry: A Podcast

By Peter D. Hardy, Beth Moskow-Schnoll & Gretchen L. Gurstelle

May 14, 2019

We are pleased to offer the latest episode in Ballard Spahr’s Consumer Financial Monitor Podcast series — a weekly podcast focusing on the consumer finance issues that matter most, from new product development and emerging technologies to regulatory compliance and enforcement and the ramifications of private litigation. In this podcast, we review the many recent developments dealing with the provision of financial services to the cannabis industry, including state approaches to banking services, the status of…

Money Laundering Watch

PLI Anti-Money Laundering Conference to Address Key Issues in BSA/AML

By Peter D. Hardy

May 6, 2019

I am really honored to be moderating the Practising Law Institute’s 2019 Anti-Money Laundering Conference in New York City on May 14, 2019, starting at 9 a.m. My co-chairs are Nicole S. Healy of Ropers Majeski Kohn & Bentley PC, and Jamie Boucher of Skadden Arps Slate Meagher & Flom LLP. PLI’s AML conference in San Fransisco will be held on June 10, 2019, and both conferences will be available throughout the country via webcasts and…

Money Laundering Watch

First Circuit Confirms Broad Civil Immunity for Filing a SAR

By Peter D. Hardy

April 29, 2019

As we previously blogged, the District of Massachusetts held in AER Advisors Inc. v. Fidelity Brokerage Services, LLC, that the safe harbor provision of the Bank Secrecy Act (BSA) provides unqualified protection to financial institutions and their employees from civil liability for filing a Suspicious Activity Report, or SAR. An update: the First Circuit recently upheld this ruling in an opinion which, consistent with the holdings of most other federal courts, clearly found that…

Peter D. Hardy

What the Basel AML Index Reveals About Global Money Laundering Risks

FinCEN Announces New “Global Investigations Division” Focused on Foreign Money Laundering Threats

FinCEN Director Blanco Addresses AML Compliance and Casinos

Former Bank General Counsel Enters into Consent Order Over Alleged AML Obstruction

OFAC’s Revised Reporting Rules Create New Compliance Requirements for All U.S. Persons

Senate Committee Hears from OCC, FinCEN and FBI on Risks Posed by Anonymous Corporate Structures

FinCEN Again Extends Real Estate GTOs

Financial Services and the Cannabis Industry: A Podcast

PLI Anti-Money Laundering Conference to Address Key Issues in BSA/AML

First Circuit Confirms Broad Civil Immunity for Filing a SAR

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