Anti-Money Laundering (AML) 101: What every attorney needs to know

Jeffrey Ziesman | Bryan Cave Leighton Paisner LLP

Jeffrey Ziesman’s practice focuses on Investment Adviser and Broker-Dealer regulatory and compliance issues. He has achieved successful outcomes for firms in SEC, FINRA and State regulatory examinations, investigations and enforcement proceedings. Mr. Ziesman also advises Investment Advisers and Broker-Dealers on compliance and supervisory issues, and has assisted firms in structuring their compliance programs and written supervisory systems and procedures. Mr. Ziesman has spoken to industry groups on a wide variety of investment adviser and broker-dealer regulatory concerns.

Mr. Ziesman is also a member of Bryan Cave’s Data Privacy and Security Team. In that capacity, he advises financial services firms on a wide array of data privacy issues, including the handling of data security breaches. Mr. Ziesman has also provided guidance to industry participants on the ever-changing requirements regarding protecting confidential customer data.

Mr. Ziesman was previously the Deputy Regional Chief Counsel for the Midwest Region of FINRA. In that capacity, he brought significant enforcement cases in such diverse areas as Regulation D, Anti-Money Laundering (AML); Regulation S-P; failure by firms to timely deliver prospectuses to customers; and supervisory controls and procedures. Mr. Ziesman brought one of the leading FINRA cases in 2011 relating to giving credit-for-cooperation, under FINRA Regulatory Notice 08-70, for a firm’s self-reporting violations. Mr. Ziesman was on Regulatory Disposition Groups for supervisory controls and AML at FINRA. In 2005, he received the FINRA Excellence in Service Award (only given to 1% of employees at FINRA) and in 2007 and 2004 was awarded FINRA President’s Award for his work on major matters.

Alma Angotti | Guidehouse

Alma Angotti is a Partner in Guidehouse’s Financial
Alma is a recognized expert in compliance and investigations with an emphasis on anti-money laundering (AML), combatting the financing of terrorism (CFT) and economic sanctions compliance.

Alma has over 10 years of consulting experience and has counselled her clients in a variety of projects, managed gap analyses, compliance program reviews, risk assessments, remediation efforts, investigations, and historical transaction reviews. Her clients include large, complex, global financial institutions, global payments institutions, mid-sized banks, broker-dealers, and Fintech and digital assets companies, hedge funds, casinos, and multinational corporations. She leads the firm’s cryptocurrency, digital assets and fintech projects.

Alma has also held interim senior compliance leadership positions at several global and regional financial institutions providing day-to-day management of their compliance programs and assisting them with remediation efforts, often in the context of a regulatory or criminal enforcement action. She has trained and advised the financial services industry and regulators and government officials worldwide on AML, sanctions, CFT, and other regulatory compliance issues.

In her 25 years of experience in regulation and enforcement, Alma held senior enforcement positions at the U.S. Securities and Exchange Commission (SEC), U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and FINRA (Financial Industry Regulatory Authority). In these positions, she was responsible for investigations and enforcement of the Bank Secrecy Act, the federal securities laws, and FINRA rules. At FinCEN and FINRA, she designed and lead the AML enforcement programs.

I. Overview of Anti-Money Laundering | 2:00pm – 2:20pm

A. Definition of Money Laundering
B. AML Regulatory Landscape
C. AML Program Requirements

II. Relevance of AML in the Legal Profession | 2:20pm – 2:40pm

A. International Application of AML Laws to Legal Profession
B. Taylor Lohmeyer Law Firm P.L.L.C. v. United States (Fifth Circuit)
C. Intersection of Practice Areas and AML

III. AMLA of 2020 | 2:40pm – 3:00pm

A. Key Changes
B. Timeline
C. Beneficial Ownership Information Reporting Requirement

Break | 3:00pm- 3:10pm

IV. FinCEN Priorities, Released June 30, 2021 | 3:10pm – 3:25pm

A. Priorities Letter and Implications from Content
B. Additional Regulatory Pronouncements, Clarification, and Regulations, Issued Regarding Priorities
C. Likely Enforcement Actions Under Priorities

V. FinCEN’s Beneficial Ownership Advance Notice of Proposed Rulemaking | 3:25pm – 3:45pm

A. Relevant Comments and Public Pronouncements
B. Updates Regarding Rulemaking
C. Other Regulatory Releases Regarding Beneficial Ownership

Vl. Other Regulatory Releases Regarding AML Issues In 2021 | 3:45pm – 4:00pm

A. SEC and FINRA Annual Examination Priorities Letters
B. FINRA Regulatory Notice 21-03, Regarding Penny Stocks and AML Risks
C. SEC March 2021 Risk Alert Regarding Suspicious Actvity Reporting at Broker-Dealers

Vll. Regulatory Enforcement Actions | 4:00pm- 4:10pm

A. Recent Relevant Cases
B. Potential Future Areas, Given Regulatory Priorities