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From the largest global financial institutions to the internet frontier, Pillsbury counsel clients in addressing the AML challenges confronting their business. Our deep and experienced team spans the globe and covers the many disciplines crucial to AML matters—financial , compliance, enforcement, investigations, and international policy.

In an age of deepening multilateral commitments • Enforcement. Pillsbury attorneys have extensive and increasing enforcement coordination, we help experience in representing financial institutions our clients understand the interplay of traditional and their officers and directors in a wide variety of AML rules, sanctions policies, counter- and regulatory enforcement actions, internal compliance counter-proliferation efforts, anti-corruption sensitiv- matters, criminal investigations and related civil ities and ever-changing technology. Our lawyers bring litigation. We also advise on U.S. criminal anti-money experience as former government compliance officials, laundering and the Secrecy Act in the context prosecutors and counsel that is critical of transactions, funds and financing. to understanding how best to advise clients in these • Sanctions. The firm’s leading U.S. and global sanctions sensitive matters. practice helps clients to address sanctions issues in the AML context and liaison with Treasury’s Office of Global AML Capacities Foreign Assets Control (OFAC). U.S. sanctions policies U.S. Anti-Money Laundering can have a dramatic impact on the activities of financial AML regulation continues to evolve and the definition Institutions (U.S., multinational or non-U.S.) and of “” continues to expand. We advise other businesses. We also advise clients on the overlap a diverse range of clients on FinCEN rules and reporting, of OFAC sanctions and FinCEN “special measures” Act and USA matters, imposed on jurisdictions and . sanctions, emerging online and digital issues, and criminal AML and enforcement. We also advise on New • AML in the Online World. We advise clients at the York state and enforcement actions. cutting edge of AML policy in the digital age—FinTech, , online financial business matters, • Federal Financial Regulation. In addition to FinCEN, and data . This includes addressing we work extensively with the Board, AML laws, and compliance obligations Treasury Department, Comptroller of the Currency, including, but not limited to, devising, implementing and Federal Deposit , Office of Thrift maintaining an AML compliance program with required Supervision, Securities and Exchange Commission and policies, procedures and controls. We also assist clients Commodity Futures Trading Commission. in conducting risk assessments in the AML context.

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This includes AML challenges relating to electronic Financial Action Task Force (FATF) banking, prepaid and gift cards, electronic payments, We are -standing observers of FATF policy trends and e-commerce, and online gambling. their effects on national AML policies around the world. EU and UK Anti-Money Laundering Laws The FATF has quietly become one of the more influential institutions in the global . Via its “FATF Throughout the (EU), and particularly Recommendations” (previously the “40 recommenda- in the (UK), AML requirements are tion”) it sets standards for AML, the counter-terrorist-fi- becoming increasingly complicated and comprehensive. nancing and counter-proliferation policy, as well as for Our attorneys, including qualified English solicitors, how governments cooperate and share information to are constantly monitoring AML developments and combat AML, sanctions and anti-corruption challenges. providing client advice in this area. Attorneys from our The FATF also assesses compliance by nations with its London office regularly liaise with the Financial Conduct recommendations and identifies countries that present Authority (FCA) on regulatory, compliance and transac- risks or require counter-measures—both of which can tional matters. Our attorneys can provide guidance in the impact banks and businesses active in, or having clients or UK on the Proceeds of Act 2002, Terrorism Act corre- spondent accounts from, such jurisdictions. 2000, Money Laundering Regulations 2017, Sanctions and Anti-Money Laundering Act 2018 and any amending Addressing AML Challenges legislation or regulations. We also monitor European • Compliance Planning. We frequently advise our clients Commission AML Directives and their impact on national on compliance planning to address AML, sanctions legal regimes within the European Union. and other regulatory challenges. On the AML side, this includes devising, implementing and/or adjusting Our attorneys are also monitoring the soon-to-be-effective policies, procedures and controls while developing replacement of the FSA by two new regulatory bodies: appropriate risk-based approaches. Our multi-disci- the Prudential Regulation Authority (PRA) and Financial plinary insights allow us to help clients integrate AML Conduct Authority (FCA). We also monitor European compliance policies and identify issues that may affect Commission AML Directives and their impact on national particular clients or industries. legal regimes within the European Union. • Internal Investigations. Our financial, regulatory and Asia and Latin America Anti-Money Laundering Laws white collar teams have the capacity to plan and execute Pillsbury’s Beijing, Hong Kong, Shanghai and Tokyo sensitive investigations in the and around offices offer experience in financial and AML rules the world. in and . Our Korea and Myanmar/Burma • Transactions and . We support funds, practice specialties also can offer AML support relating financial institutions, private groups, and to either of those countries. Finally, we have broad traditional businesses in addressing AML and related experience in and an established network of local challenges in the context of transactions. These are law firms to address AML and financial regulatory issues. key deal-risk issues and we offer clients both legal knowledge and practiced judgment in the transac- Our Latin America team has experience throughout tional context. the Americas and can advise on AML issues that arise anywhere in the Western Hemisphere. Our attorneys • White Collar Defense. Should regulators, prosecutors, regularly practice in Spanish and Portuguese and have government investigators or legislative committees a deep understanding of the culture and sensibilities of probe our client’s activities, our team has the capacity to this region. advise, prepare and defend our clients.

Pillsbury Winthrop Shaw Pittman LLP Anti-Money Laundering

Representative Anti-Money Laundering Matters • Advised cruise line with gambling operations on Compliance Planning various aspects of U.S. anti-money laundering rules • Revised Know-Your-Customer (KYC) sanctions including casino AML programs, currency transfer, guidelines for leading global provider of business, legal, money services business, customer due diligence and and . other matters. • Assisted numerous money transmitters in compliance • Provided advice to multiple banks in Cyprus with BSA, AML and OFAC regulations, including but not regarding improving their AML and sanctions limited to assisting on risk analysis and implementing compliance programs. policies and procedures. • Advised multiple Thai banks on anti-money laundering • Provided on going advice on AML compliance and and sanctions considerations for lending and transac- considerations while building various payment and tions in Myanmar. blockchain- related products and services. • Conducted compliance review for Swiss bank focusing • Provided advice to Middle Eastern free trade zone on anti-money laundering issues. regarding improvement of their AML and sanctions • Advised non-U.S. bank on the applicability of U.S. AML compliance programs, including a review of best rules on its affiliated U.S. investment advisory firm. practices among “off-shore” and entity-forming jurisdic- tions in the wake of the Papers revelations. • Advised large U.S. leasing and company with a Japanese parent on in its AML policies related to • Helped one of the world’s largest financial institutions equipment purchase and export transactions. prepare AML compliance policies to address foreign currency controls. • Advised a client on the AML and sanctions compliance policies of subsidiary online-payment and prepaid- • Worked with the prepaid card business to card businesses. AML policies and procedures. Reviewed and revised policies and procedures and put into place applicable • Assisted on KYC, Customer Identification Program remediation efforts. (CIP) and Enhanced Due Diligence (EDD) reviews and programs. • Advised a major U.S. regional bank regarding OFAC and AML compliance obligations with respect to • Conducted due diligence, including but not limited to maintaining accounts for Iranian Non-Resident Alien BSA, AML and OFAC compliance of potential targets students in the United States. or partners • Obtained money transmitter licenses and assisted Investigations on related MSB Registration requirements for • Advised prior shareholder of a Swiss banking institution numerous companies. on exposure associated with various DOJ global money laundering investigations, including FIFA, 1MDB, • Assisted domestic and international escrow companies, , Petrobras and PDVSA. money transmitters and money services businesses on compliance with BSA, AML and OFAC recordkeeping • Represented major international financial institution in and reporting. money laundering investigation involving correspondent bank accounts of entity; no criminal or • Advised blockchain companies on federal and state BSA, enforcement action was ultimately pursued. money transmitter and bit-license requirements. • Represented a prominent multinational bank in parallel • Assisted retailers on compliance with BSA Prepaid investigations of alleged terrorist financing and money Access Rules, as well as rewards and gift card programs. laundering by the U.S. Department of Justice and Office • Assisted gaming and gambling companies on compliance of the Comptroller of the Currency; devised enhanced with BSA in relation to virtual currency or closed loop. internal controls, including additional know-your-cus- tomer rules for correspondent accounts.

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• Represented major international financial institutions • Provided advice to multiple banks in Cyprus based in the UK and the Netherlands in various DOJ and regarding improving their AML and sanctions NY district attorney investigations. compliance programs. • Represented a publicly traded payment processor in a • Advised the Ras Al Khaimah Investment Authority on criminal grand jury investigation involving the United the sale of the Poti FIZ to the Government of Georgia. States Attorney’s Office in the Southern District of • Provided advice to Middle Eastern free trade zone New York regarding the processing of transactions for regarding improvement of their AML and sanctions ‘‘e-wallets.” An ‘‘e-wallet’’ is an online merchant that compliance programs, including a review of best allows customers to deposit, withdraw and transfer practices among “off-shore” and entity-forming jurisdic- funds to pay for their online purchases. tions in the wake of the Panama Papers revelations. • Represented multiple relationship managers in • Represented major international financial institution in connection with a Panama Papers investigation. money laundering investigation involving correspondent • Represented major international financial institution bank accounts of offshore bank entity; no criminal or in DOJ forfeiture action involving correspondent bank enforcement action was ultimately pursued. accounts; forfeiture was vacated. • Advised non-U.S. bank on the applicability of U.S. AML • Represented major financial institution in investigation rules on its affiliated U.S. investment advisory firm. of alleged senior mismanagement of subsidiary . • Advise client on AML, sanctions and other legal issues • Represented a money/check processor in connection for opening of new FinTech payments services in Russia with a Department of Justice investigation of money and Turkey, and third-party payment and ticket services laundering and online gambling; no criminal or in the United States. enforcement action was ultimately pursued. • On behalf of the Association of Cyprus Banks (the • Acted as co-counsel for large international bank trade association for banks in Cyprus), managed a on criminal and civil BSA and AML charges and large-scale image campaign to educate U.S. regulators forfeiture actions. about improvements in Cyprus’ AML and sanctions compliance framework. • Defended large international money transmitter on criminal and civil BSA and AML charges. • Represented a number of Swiss banks in a program led by the DOJ and the to • Represented banks in BSA/AML examinations and identify violations of US laws, with a specific focus potential regulator actions by bank examiners, including on US-related accounts held at those banks. After OCC, FDIC and state banking authorities. conducting comprehensive internal investigations, we • Assisted banks and non-banks on obligations to comply succeeded in negotiating non-prosecution agreements (and limitations on such obligations) to law enforcement for each of these banks. The Swiss Banks voluntarily demands for information. participated in this program that is officially known • Assisted money transmitters in connection with seizures as the Program for Non-Prosecution Agreements or of funds by federal and state law enforcement agencies. Non-Target Letters for Swiss Banks. Representative Experience in Cyprus, the , • On behalf of the Cayman Islands Ministry of Financial and Ras Al Khaimah Services and Home Affairs, spearheaded a campaign • Experience with cross-border transactions involving to educate U.S. lawmakers regulators about Cayman’s numerous countries, including , Bahrain, robust financial regulatory regime and its tax Canada, the Cayman Islands, China, Dubai, Egypt, transparency framework, while dispelling outdated , Belgium, , Honduras, India, Israel, and inaccurate perceptions of Cayman as a secrecy Jordan, , Malaysia, the Netherlands, jurisdiction. Pakistan, the Philippines, Saudi Arabia, Serbia, , Spain, Switzerland and Turkey.

Pillsbury Winthrop Shaw Pittman LLP Anti-Money Laundering

• Represented a former Central American FIFA soccer About Pillsbury officer in a widely-publicized international DOJ inves- Pillsbury Winthrop Shaw Pittman LLP is an international tigation involving allegations of cross-border money law firm with a particular focus on the technology & laundering and fraud related to the sale of TV and media, energy, financial services, and real estate & other media rights for World Cup soccer matches in construction sectors. Recognized as one of the most Central America. innovative law firms by Financial Times and one of the top firms for client service by BTI Consulting, Pillsbury and • Represented a former employee of a money processor its lawyers are highly regarded for their forward-thinking in connection with a DOJ investigation for international approach, their enthusiasm for collaborating across money laundering allegedly involving operations disciplines and their authoritative commercial awareness. in Panama, the United States, the United Kingdom and India. Global Trade & Sanctions Law Blog • Represented major international financial institution in For news and insights on all issues related to international money laundering investigation involving correspondent trade and sanctions activity, please visit our blog at bank accounts of offshore bank entity; no criminal or www.globaltradeandsanctionslaw.com enforcement action was ultimately pursued.

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