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Dirty Money Is Dirty Money: The BSA Responsibilities that Casinos and Banks Have in Common

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MoFo partner Deb Connor spoke on a panel titled, "Dirty Money Is Dirty Money: The BSA Responsibilities that Casinos and Banks...

MoFo partner Deb Connor spoke on a panel titled, "Dirty Money Is Dirty Money: The BSA Responsibilities that Casinos and Banks Have in Common," at the ACAMS Assembly Las Vegas conference on September 23, 2024. Deb and her co-presenters discussed the legal and regulatory responsibilities shared by banks and casinos, especially regarding the Anti-Money Laundering Act of 2020. Together they shared how to mitigate the chance of dirty money finding its way into your institution, including how to meet BSA obligations, enhance due diligence, and use a risk-based approach to terminate a customer relationship. Read more on the <a href="https://www.acams.org/en/events/the-assembly/the-assembly-las-vegas#speakers--task-force-33bce004" target="_blank">event website</a>. <hr>

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Deborah L. Connor, former chief of the Money Laundering and Asset Recovery Section (MLARS) of the U.S. Department of Justice (DOJ), is a partner in MoFo’s Investigations + White Collar Defense Group. With more than 25 years of service at DOJ, most recently leading its anti-money laundering (AML)/Bank Secrecy Act (BSA) enforcement, Deborah is a leading authority in criminal AML/BSA matters. Drawing upon her unmatched experience in criminal investigations, litigation, and enforcement, Deborah focuses on guiding financial institutions, multinational companies, and individuals through cross-border internal investigations, regulatory enforcement defense, white collar criminal defense, and compliance counseling involving legal issues pertaining to sanctions, anti-corruption, AML/BSA, and cryptocurrency, among others.As chief and principal deputy chief of MLARS, Deborah supervised investigations and prosecutions of numerous high-profile cases involving allegations of corporate and financial misconduct and resolutions involving deferred prosecution and non-prosecution agreements in relation to financial institutions and emerging technologies in the financial services markets, as well as blockchain-based digital assets. As chief, she exercised supervisory authority over the DOJ’s AML program, specifically any charges involving violations of BSA statutes. Deborah has worked with domestic regulators, including the Financial Crimes Enforcement Network, the Office of the Comptroller of the Currency, the Federal Reserve, and the Office of Foreign Assets Control, as well as enforcement officials throughout the federal government, including the Departments of State, Commerce, and Treasury. She was also responsible for helping to oversee the Department’s Asset Forfeiture Program. Deborah also served as senior counsel to the assistant attorney general for the Criminal Division.Prior to joining the Criminal Division, Deborah had a distinguished 16-year career as an assistant U.S. attorney in the U.S. Attorney’s Office for the District of Columbia, where she held several leadership positions and supervised hundreds of prosecutors. In her last five years with the office, Deborah served as chief of the Fraud and Public Corruption Section, where she supervised the office’s white collar prosecutions including complex AML and sanctions evasion investigations and prosecutions against global financial institutions and their employees, civil and criminal forfeiture cases, and major financial fraud actions involving corporations and government agencies. As a criminal prosecutor, Deborah has investigated a broad range of white collar and other federal criminal matters, tried over 40 criminal trials in both D.C. Superior and Federal Courts, supervised more than 100 criminal trials, and briefed and argued criminal appeals. Deborah began her career at DOJ as a civil trial attorney in the Antitrust Division’s former Computers and Finance Section.Deborah received numerous awards while at DOJ, including five Special Achievement Awards, and the United States Attorney’s Star Award in the U.S. Attorney’s Office. During her time at the Criminal Division, Ms. Connor twice received the Assistant Attorney General’s Exceptional Service Award and the Assistant Attorney General’s Award for Distinguished Service. In 2021, Deborah was named one of Global Investigations Review’s (GIR) Top 100 Women in Investigations.Prior to joining DOJ, Deborah was a litigation associate at a large D.C.-based law firm, and before entering the practice of law, she joined a large Chicago-based commercial bank, where she served as a relationship manager for U.S. subsidiaries of multinational corporations.Deborah is a frequent speaker on AML and financial crimes enforcement. She has participated as a keynote speaker or panelist at conferences such as the American Bar Association’s (ABA) National Institute on White Collar Crime, ABA’s Financial Crimes Enforcement Conference, the Association of Certified Anti-Money Laundering Specialists’ (ACAMS) Annual AML & Anti-Financial Crime Conference, the Practising Law Institute, and the American Gaming Association.Deborah received her J.D. cum laude from Georgetown University Law Center, where she served on the Georgetown Law Journal as a notes editor. She received her B.A. from Miami University of Ohio.<h4>Representative Experience</h4><ul><li>Supervised the investigation and resolution of a matter involving a global financial institution and its European subsidiary related to fraud on financial investors. The matter resulted in a deferred prosecution agreement with the parent and a guilty plea with a subsidiary, guilty pleas of three employees, financial penalties, fines, and disgorgement.</li><li>Supervised the investigation and resolution of a matter involving a global financial institution and a foreign subsidiary in connection with bond deal underwriting. The matter resulted in a deferred prosecution agreement, a guilty plea for a subsidiary, financial penalties, and the conviction of two former high-level employees.</li><li>Supervised the investigation and resolution of a matter involving a foreign sovereign wealth fund, as part of the misappropriation of over $4.5 billion from the fund. The matter resulted in seizures of over $1.7 billion in assets as part of a civil forfeiture recovery.</li><li>Supervised the investigation and resolution of a matter involving a foreign financial institution related to a money laundering conspiracy in connection with a bribery scheme. The matter resulted in a deferred prosecution agreement, financial penalties, forfeiture, and the guilty pleas of two employees.</li><li>Supervised the investigation and resolution of a matter involving a foreign financial institution related to the processing of transactions in violation of U.S. sanctions. The matter resulted in a parent-level guilty plea and a non-prosecution agreement with a subsidiary, in addition to forfeiture.</li></ul>

Dirty Money Is Dirty Money: The BSA Responsibilities that Casinos and Banks Have in Common

23 Sep 2024 - 25 Sep 2024