Financial Crime & Economic Sanctions

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Today’s financial institutions face unprecedented challenges from both illicit actors attempting to exploit the global financial system and government regulators who demand that those institutions maintain effective financial crime and sanctions compliance programs. Companies that do not meet those obligations could face serious enforcement actions, significant fines, costly remediation requirements, reputational risk, and even criminal liability. 

Bradley’s interdisciplinary team provides regulatory compliance counseling and enforcement services related to the Bank Secrecy Act and anti-money laundering (BSA/AML), countering the financing of terrorism (CFT), bribery, and economic sanctions. Our lawyers have extensive knowledge and deep experience working with financial institutions across the regulatory spectrum. Our partners have worked at the Department of Justice (DOJ), in regulatory agencies such as the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA), and as senior in-house counsel at major financial institutions and exchanges.

Bradley’s Financial Crime and Economic Sanctions practice works with a diverse range of financial institutions, including banks, broker-dealers, mortgage lenders and consumer lenders, to develop risk-based BSA/AML and economic sanctions compliance programs and, if necessary, vigorously defend clients from government investigations or enforcement actions.

Our services include:

Bradley advises clients on laws and regulations governing economic sanctions and financial crime compliance, including the BSA as amended by the USA PATRIOT Act, the Anti-Money Laundering Act of 2020, Financial Crimes Enforcement Network (FinCEN) regulations, Office of Foreign Asset Control (OFAC) sanctions, and federal and state criminal money-laundering statutes.

We work closely with clients to develop or enhance existing BSA/AML and sanctions compliance programs to help avoid regulatory scrutiny and government investigation. Bradley can evaluate an institution’s risk profile and create a risk-based program, including drafting compliance policies and procedures, advising companies on transaction monitoring and suspicious activity detection, evaluating Know Your Customer (KYC) programs, and even working with compliance technology vendors. And because compliance programs are only effective when properly implemented, Bradley can design and deliver training programs targeted at front-line business employees, compliance personnel, or company executives and board members.  

Bradley’s financial crime and economic sanctions team is often called upon to independently review existing compliance programs or work alongside a company’s audit committee to evaluate the sufficiency and effectiveness of those programs. By engaging Bradley to scrutinize your compliance program, any identified deficiencies are more likely to be covered by attorney-client privilege and not subject to later disclosure.  
Companies must be wary to avoid risk and liability associated with deficiencies in a counter-party’s financial crime compliance program. Bradley’s attorneys can conduct mergers and acquisition due diligence to ensure compliance with BSA/AML laws and regulations, economic sanctions, and both domestic and foreign anti-bribery laws. 
Bradley is among the nation’s leading law firms when it comes to representing financial institutions in regulatory examinations. This extends to examinations focused on BSA/AML deficiencies. Whether it is the Office of the Comptroller of the Currency (OCC), the Federal Reserve, FinCEN, or a state regulator, our attorneys help guide banks and other institutions through examinations and, if necessary, assist with remedial actions.
Bradley attorneys conduct internal investigations into BSA/AML violation allegations, employee misconduct regarding financial crime compliance, and customer relationships and transactions that may pose BSA/AML or sanctions risks. Our team includes a former federal prosecutor who served as a Suspicious Activity Report (SAR) coordinator and can advise financial institutions on when and how best to file a SAR with FinCEN and, if necessary, coordinate with law enforcement. As with compliance program reviews, engaging counsel to lead sensitive internal investigations helps protect the findings from later disclosure. Depending on the outcome of the investigation, Bradley’s team can expertly advise companies on whether and how to self-disclose those findings to the government.
Bradley represents financial institutions in both criminal and civil enforcement actions conducted by federal and state authorities, including the DOJ, U.S. Attorneys’ Offices, SEC, state attorneys general, and other federal and state authorities. We work tirelessly to defend our clients in BSA/AML, OFAC, and Foreign Corrupt Practices Act (FCPA) investigations and prosecutions, mitigating potential damages and negotiating the most favorable outcomes possible. Our attorneys also have experience representing financial institutions in Congressional investigations or other legislative inquiries and providing crisis management and strategic response services.