Advice built around the complete record.
Financial-crime matters can move from an internal alert to a government investigation with little warning. A payment may raise sanctions, money-laundering, terrorism-financing, fraud, forfeiture and regulatory questions at the same time. We create a privileged command structure and a common factual record so the client can respond accurately without allowing one workstream to undermine another.
The practice covers 18 U.S.C. §§ 2339A and 2339B, the Bank Secrecy Act, USA PATRIOT Act Sections 311 and 314, OFAC programs, correspondent banking, trade-based money laundering, hawala, informal value transfer and digital assets. We advise on legal elements, knowledge and intent, beneficial ownership, transaction purpose, wallet attribution, program delivery and the timing of designations or authorizations. Labels and screening scores are treated as investigative leads, not conclusions.
For institutions, the work also addresses governance and control effectiveness. Risk assessments, customer and counterparty diligence, monitoring, screening, investigations, SAR decision processes, quality assurance, testing and remediation are examined as one system. For individuals and organizations under investigation, the team preserves evidence, prepares witnesses, analyzes government process and evaluates whether a focused presentation, administrative petition, negotiation or litigation is appropriate.
Who we advise
We represent banks, MSBs, fintechs, crypto exchanges, charities, NGOs, boards, executives and individuals. Each client sees a different part of the financial chain. Our work connects customer, payment, operational and government information without assuming that any single data source establishes control, knowledge or intent.
Humanitarian and nonprofit matters receive a calibrated review of donors, partners, beneficiaries, procurement, cash, financial routes, licensing and end-use monitoring. The objective is to address genuine diversion or prohibited-party risk while preserving lawful activity and avoiding unsupported de-risking.
