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Rethinking Anti-Money Laundering Risk & Compliance

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Deborah Connor, Marc-Alain Galeazzi, and Dillon Guthrie authored an article for Industry Today discussing the recent congressional expansion of an anti-money laundering (AML) whistleblower rewards program to cover reported violations of U.S. sanctions laws, and how companies should revisit and revitalize their compliance programs in these areas.

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Deborah Connor, Marc-Alain Galeazzi, and Dillon Guthrie authored an article for Industry Today discussing the recent congressional expansion of an anti-money laundering (AML) whistleblower rewards program to cover reported violations of U.S. sanctions laws, and how companies should revisit and revitalize their compliance programs in these areas.“In addition to potential enforcement actions, whistleblower reports can result in a variety of additional concerns, including greater overall regulatory scrutiny, expensive internal investigations, and potentially far-reaching environmental, social, and governance and associated reputational risks,” the authors wrote. “Businesses facing exposure under the recent AML laws should, therefore, reevaluate their AML and sanctions practices.”They added: “Manufacturers and other companies should maintain an AML program incorporating what are known as the four basic pillars of sound AML risk management: (1) a designated compliance officer; (2) internal policies, procedures, and controls; (3) personnel training; and (4) independent testing and review. These pillars support one overarching goal: a risk-based program that encourages a culture of compliance from the top down and is commensurate with a company’s exposure and complexity.”Read the <a href="https://industrytoday.com/rethinking-anti-money-laundering-risk-compliance/" target="_blank">full article</a>.

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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>

Deborah Connor

Partner

Marc-Alain’s practice focuses on advising and counseling domestic and foreign financial institutions on a variety of bank regulatory, Bank Secrecy Act/anti-money laundering (BSA/AML), countering the financing of terrorism (CFT), and transactional matters. Marc-Alain has significant experience representing global financial institutions in criminal and regulatory investigations and enforcement actions as well as addressing weaknesses and shortcomings in their BSA/AML compliance frameworks. He also advises clients on all AML-related issues in connection with ESG, M&A, strategic investments and private equity funds, embedded finance, blockchain and digital assets, and other corporate transactions. Marc-Alain is adept at assisting clients to build ground up BSA/AML policies and procedures, and he works closely with banks and fintechs to navigate BSA/AML considerations related to Banking-as-a-Service (BaaS) and other partnership arrangements.Further, Marc-Alain has significant experience in advising and counseling U.S. and international bank holding companies, banks, and other financial institutions on a variety of bank regulatory and transactional matters, including matters relating to:<ul><li>The Bank Holding Company Act</li><li>Regulation K and Y</li><li>The Bank Merger Act</li><li>The Dodd–Frank Act (with regard to the Volcker Rule, Living Wills, and Enhanced Prudential Standards, among others)</li><li>Applications to federal and state banking regulators for expansion of activities</li><li>Internal restructuring</li><li>New products, sales, and acquisitions of U.S. banks</li></ul>Prior to joining Morrison Foerster, Marc-Alain was an associate with two prominent global United States law firms, and he practiced law in Switzerland for several years.Marc-Alain is a member of the board of the Swiss American Lawyers Association of Greater New York (SALA). He is fluent in German, English, French, and Spanish and has a basic knowledge of Italian. He is admitted to practice in New York and Switzerland.