Anti-Money Laundering and Financing of Terrorism Compliance and Enforcement

Navigating AML and CFT risk

The global regulatory landscape for AML and CFT compliance is increasingly complex, influenced by geopolitical dynamics, changing regulations, and heightened enforcement activity. Civil penalties, criminal exposure, and reputational damage can arise quickly when controls lag behind regulatory expectations.

Drawing on a global, cross-disciplinary team that includes former senior officials from the Department of Justice, Department of the Treasury, Department of Defense, as well as former financial regulators, DLA Piper helps companies anticipate regulatory shifts, respond to investigations, and develop sustainable risk management strategies across their enterprise.

Building resilience through compliance

Our lawyers, compliance professionals, and Certified Anti-Money Laundering Specialists design and implement pragmatic, risk-based programs tailored to each organization’s profile – whether a traditional financial institution, fintech innovator, private fund, insurer, blockchain platform, or precious metals dealer. We frequently engage with regulators and law enforcement agencies on complex legal developments, and we help businesses navigate this dynamic landscape with tailored compliance programs and strategic defense capabilities.

• Designing and Executing Global Compliance Programs. Spearheaded the development and implementation of risk-based compliance frameworks for global corporations operating in multiple jurisdictions, handled comprehensive risk assessments, tailored policies and procedures, and targeted training initiatives addressing AML, economic sanctions, export controls, anti-bribery (including the Foreign Corrupt Practices Act), anti-fraud, and customs regulations across diverse international operations.


• Advising Blockchain and Technology Clients on AML/CFT. Counseled leading blockchain and technology companies on AML and CFT compliance, including the design of controls to mitigate money laundering and illicit activity risks in both online and on-chain environments, and facilitated proactive engagement with law enforcement agencies to address emerging threats.


• Litigation and Regulatory Defense for Global Financial Institutions. Represented major global banks in high-stakes federal litigation involving the adequacy and effectiveness of AML and sanctions compliance controls, with a particular focus on CFT obligations and regulatory expectations.


• Cutting Edge Guidance for Today’s AML/CFT Environment.
  Designing crisis and risk management strategies for US and Latin American financial institutions and other companies following the US designation of Mexico-based drug cartels as foreign terrorist organizations and specially designated global terrorists and FinCEN’s FEND Off Fentanyl Act orders identifying three Mexican financial intermediaries as primary money laundering concerns.


• Training and Capacity Building for International Stakeholders. Developing bespoke CFT training programs for judicial and prosecutorial authorities from an EMEA country designated on the Financial Action Task Force (FATF) “gray list,” enhancing institutional capacity to detect and combat terrorist financing and related crimes.


• Conducting Complex Internal and Regulatory Investigations. Lead internal and government-facing investigations and compliance reviews for clients in highly regulated sectors, including:


• A private equity firm and registered investment adviser through a multi-agency review of US sanctions and export controls compliance related to Russia and Ukraine, resulting in a no-action letter from OFAC.


• A blockchain company on compliance program enhancements regarding the retention of IT and programming staff from comprehensively sanctioned jurisdictions, culminating in a favorable outcome with no enforcement action by OFAC.


• A multinational financial institution, focusing on AML and CFT compliance with DOJ and SEC requirements, and the institution’s high-risk customer segments in the Middle East and Asia.


• A commodities trading and energy company, advising on adherence to US foreign trade regulations, including matters before the US Commerce Department’s Bureau of Industry and Security.


• A global investment bank, defending it against potential criminal prosecution by local authorities for alleged AML and tax evasion violations, while safeguarding the interests of both the parent company and its foreign subsidiary.