Corporate Transparency Act's Impact on Banking: Ensuring Compliance; Interplay With Know Your Client Due Diligence Rules

Mr. Fornaris is co-chair of the Financial Services Practice and co-chair of the Digital Assets and Blockchain Technology Group. With nearly 30 years of legal experience, he advises a broad range of financial services firms, including banks and their holding companies, trust companies, money services businesses, payments and FinTech companies, cryptocurrency and other digital assets firms, investment advisers, securities broker dealers, gaming firms, and other financial institutions and institution-affiliated parties, including financial institution officers and directors, on all aspects of their business. He represents clients in an extensive range of regulatory, transactional, and administrative enforcement matters, including institution formation and licensing, capital-raising transactions, acquisitions and divestitures, Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance and The Office of Foreign Assets Control (OFAC) sanctions programs—including the Corporate Transparency Act (CTA)—cryptocurrency regulation, payments and FinTech, Dodd-Frank Act compliance, failed bank receivership and resolution advice, and federal and state agency enforcement proceedings.

Ms. Goldstein focuses her practice on anti-money laundering and sanctions regulatory compliance matters. She advises banks, broker-dealers, investment advisers, funds, insurance companies and money services businesses, including those involved in global e-commerce and virtual currency, on the anti-money laundering and sanctions regulations, rules and related issues governing their investment and business activities. She has particular expertise with issues arising out of the Bank Secrecy Act, as amended by the USA PATRIOT Act, the AML Act of 2020 and the Corporate Transparency Act. Prior to joining SRZ, Ms. Goldstein was an attorney-advisor with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). At FinCEN, she assisted in the development of anti-money laundering regulations and guidance and served as counsel on enforcement actions involving issues such as failure to implement and maintain an adequate anti-money laundering compliance program, failure to register as a money services business and failure to maintain confidentiality of suspicious activity reports.

Ms. Freeny, a skilled trial attorney and former federal prosecutor for the Special Counsel’s Office and the Department of Justice’s Money Laundering and Asset Recovery Section, draws on more than a dozen years of high-profile experience in the federal government to help clients navigate sensitive government and internal investigations, criminal and civil enforcement matters, and related complex litigation. She has particular experience in matters involving complex financial crime, cross-border investigations, anti-money laundering, anti-corruption, economic sanctions, asset forfeiture, and affirmative challenges to federal agency action. Ms. Freeny counsels clients facing scrutiny from DOJ, the SEC, FinCEN, and other law enforcement and financial regulatory agencies. She conducts internal investigations on a range of issues and advises clients on a wide array of anti-money laundering, anti-corruption, and other compliance issues.