Bank Secrecy Act, Anti-Money Laundering, and OFAC Compliance: Recent Enforcement Actions and Regulatory Updates

Ms. Capone’s practice focuses on advising multinational corporations and financial institutions on Bank Secrecy Act/anti-money laundering (BSA/AML), anti-corruption, sanctions, payments, and consumer financial regulatory and enforcement matters, with a particular focus on regulatory matters impacting banks, casinos, social media and gaming platforms, marketplaces, fintech, payment service providers, and digital assets businesses. She regularly advises clients on the implementation, enhancement, and assessment of their compliance programs and internal controls and on platform terms and conditions. Ms. Capone frequently provides clients with training on financial services regulations and corporate compliance programs, including enforcement trends, industry best practices, and regulator expectations. She has significant experience representing clients in white collar and regulatory matters involving the DOJ, SEC, FinCEN, OCC, OFAC, the Federal Reserve, and state financial services regulators. Ms. Capone has successfully defended global clients in multi-jurisdictional and multi-agency enforcement matters involving FCPA, AML, consumer financial, securities, fraud, and sanctions allegations.

Ms. Charlton’s practice focuses on consumer financial services and regulatory and compliance matters for banks, fintech's and non-bank businesses partnering with banks or other financial institutions to provide financial services to their customers. She advises on a wide range of topics including regulatory relations and examination management, consumer facing documents and agreements, licensing requirements on the state and federal level, Anti-Money laundering and sanction programs. Ms. Charlton brings over 39 years of experience in the financial services industry, with more than 34 years specializing in compliance, legal, and risk management. Before joining the firm, she served as Head of Compliance at a regional bank, where she led regulatory oversight, risk mitigation, and enterprise-wide compliance initiatives. Ms. Charlton has a deep understanding of banking regulations including Fair Lending and Community Reinvestment Act (CRA), licensing provisions, Anti-Money Laundering & Countering Terrorist Financial (AML/CTF), and privacy laws, including GLBA, EU data protection standards, and state data breach notification laws. She is a Certified Regulatory Compliance Manager (CRCM) and a Certified Enterprise Risk Professional (CERP). With a strong background in developing and overseeing strong compliance programs, mitigation and remediation of regulatory exam findings, conducting risk assessments, and advising on corporate governance, she provides strategic counsel to clients in the financial sector. Ms. Charlton has also facilitated online courses for the American Bankers Association since July 2000 and has taught Law & Banking Foundations, Principles of Banking, Law and Banking: Applications and Law and Banking: Principles. Further, she has served as a textbook editor for the American Bankers Association (e.g., “Law and Banking” text, 5th and 7th Editions; “Banking and Finance Terminology,” 5th Edition).

Mr. Stipano provides assistance in establishing, maintaining and monitoring anti-money laundering/countering the financing of terrorism (AML/CFT) compliance programs, conducts investigations and represents clients in regulatory matters, including state and federal regulatory enforcement actions. His regulatory and enforcement experience includes more than 30 years at the Office of the Comptroller of the Currency (OCC). As Deputy Chief Counsel from 2000 to 2016, Mr. Stipano played a key role in significant Bank Secrecy Act (BSA) rulemakings and policy issuances and oversaw major OCC enforcement actions. Prior to that, he served as the Director of Enforcement. Mr. Stipano has testified six times before Congress on enforcement and AML/CFT matters. He is a member of the advisory boards of ACAMS and the ABA/ABA Financial Crimes Enforcement Conference.