We regularly represent officers, senior executives and employees of multinational banks in investigations concerning a range of bank regulations, such as Bank Secrecy Act/Anti-Money Laundering (BSA/AML) and Office of Foreign Assets Control (OFAC) statutes and rules. These investigations are often prompted by exams by various banking authorities, including the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC), and by whistleblower complaints or even self-disclosure of apparent violations. Frequently, the U.S. Department of Justice and local federal prosecutors are involved as well.
Our clients have included:
- A senior treasury executive at a major financial institution in a BSA/AML review of foreign correspondent banking practices and Know Your Customer (KYC) and Suspicious Activity Report (SAR) protocols.
- A managing director and general counsel of a prominent, multinational bank in an investigation of Enron-financing practices.
- A senior manager, traders, and salespersons at various major multinational banks in connection with internal and Department of Justice investigations into potential manipulation of the foreign exchange market.
- Senior officers and employees of a global financial services firm in a multi-agency investigation concerning BSA/AML controls.
- A managing director of a large multinational bank in a fraud investigation, pursued by foreign authorities, related to the collapse of a food conglomerate.