Anti-Money Laundering

Williams & Connolly has broad experience in regulatory, civil, and criminal anti-money laundering (“AML”) matters.  The firm represents U.S. and multinational companies from all industries, as well as senior executives. 

The firm represents clients in criminal investigations and prosecutions.  The firm also advises clients in connection with compliance and regulatory enforcement actions involving the Office of Foreign Asset Control (“OFAC”), United States Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), the New York Department of Financial Services (“NYDFS”), and other federal and state agencies.  

Economic Sanctions

Williams & Connolly provides compliance advice and represents clients in criminal and administrative matters involving alleged violations of a wide range of statutes and regulations governing banking and exports, including the International Emergency Economic Powers Act (“IEEPA”), the Trading with the Enemy Act, the Cuban Asset Control Regulations, the Helms-Burton Act, OFAC sanctions, the Bank Secrecy Act (“BSA”), and the Patriot Act.

Representative Experience

Though all cases vary and none is predictive, recent representations include:

• MoneyGram in a Department of Justice (“DOJ”) criminal investigation into allegations related to its AML controls.  The client resolved the case with the entry of a deferred prosecution agreement.
• A financial services company in connection with investigations by FinCEN and a U.S. Attorney’s Office regarding the adequacy of its AML controls.  Williams & Connolly conducted an internal investigation and helped the company successfully resolve both the regulatory and criminal investigations.
• The former CEO of an international bank in cross-border investigations regarding AML compliance, including U.S. criminal and NYDFS investigations.  
• A major money transfer agent in a multi-state AML and BSA compliance investigation.  The client avoided a criminal disposition and entered into a favorable civil resolution.
• A prominent family and their businesses in a DOJ investigation into allegations of potential AML violations, stemming from the Gupta-Zuma investigations in South Africa. 
• A Fortune 100 client in an OFAC investigation concerning its transportation business.  The firm secured a no action letter with no penalty from OFAC.
• An international bank charged in federal court with AML and sanctions violations.
• A Central American business owner and multi-national enterprises in various OFAC matters, including at trial and in administrative actions before OFAC.
• Multiple matters for business entities and individuals challenging OFAC designations under IEEPA or other sanctions regimes.