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919 Third Avenue
New York, New York 10022
United States of America
P: +1 212.756.2587
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Betty Santangelo is a partner in the New York office where the focus of her practice is white-collar criminal defense and securities enforcement. A former assistant U.S. attorney for the Southern District of New York, where she specialized in securities and commodities fraud prosecutions, Betty’s practice includes representing financial institutions, corporate entities and individuals in matters brought by the U.S. attorney’s offices, by various regulatory agencies, including the SEC, the CFTC, FINRA and SIGTARP, and by state and local prosecutors, as well as conducting internal investigations for these entities. She has also served as an independent consultant in SEC enforcement matters. Prior to joining SRZ, Betty served as first vice president and assistant general counsel for Merrill Lynch, representing the firm and its employees in enforcement proceedings before federal and state regulatory agencies, and in criminal matters before U.S. attorney’s offices and state prosecutors, as well as in foreign jurisdictions. Betty has served as division director of the ABA Litigation Committee, and as chair of its Securities Litigation and Broker-Dealer Subcommittees. She has contributed a chapter on “Representation Prior to Indictment" in the book Defending Federal Criminal Cases: Attacking the Government's Proof (Incisive Media, 2009). Betty is listed in The Best Lawyers in America and New York Super Lawyers, two of the most respected listings of lawyers, by practice area, who have attained a high degree of peer recognition and professional achievement. In 2009, the New York Chapter of the National Organization for Women presented her with its annual Women of Power and Influence Award.
Nationally recognized for her expertise in corporate compliance issues, including anti-money laundering, OFAC and FCPA, Betty’s representation of financial institutions in white collar and regulatory matters frequently draws on these areas of expertise, including advising financial institutions on their anti-money laundering/OFAC/FCPA procedures. At Merrill Lynch, she was responsible for oversight of all Bank Secrecy Act reporting and anti-money laundering activities, and the implementation of Merrill Lynch’s anti-money laundering procedures. Among Betty’s many professional activities, she has served as the Securities and Futures Industry’s representative on the Bank Secrecy Act Advisory Group of the U.S. Department of the Treasury, and is currently counsel to the Securities Industry and Financial Markets Association’s (SIFMA) Anti-Money Laundering and Financial Crimes Committee. In 1998, the Financial Crimes Enforcement Network of the United States Treasury Department awarded Betty its Director’s Medal for Exceptional Service. That same year, Betty represented the U.S. securities industry at the Financial Action Task Force (“FATF”) meeting in Brussels, Belgium. In 2002, she represented SIFMA, the Futures Industry Association and the Investment Company Institute at the FATF meeting in Paris. A former adjunct professor at Fordham Law School, where she taught a course on money laundering, Betty is a much-sought-after speaker on corporate compliance, anti-money laundering/OFAC/FCPA, white-collar criminal and securities law issues. From the Emerald Literati Network she received an “outstanding paper” award in 2006 for an article she wrote on money laundering enforcement actions and a “highly commended” award in 2011 for an article she wrote on beneficial ownership information and USA PATRIOT Act obligations. In 2008, she won a Burton Award, which recognizes exceptional legal writing, for an article she wrote on the FCPA.
Selected Representations
Internal investigation into possible money laundering and foreign tax fraud by foreign institutional client of U.S. commercial bank.
Represented global financial institution in international money laundering investigation.
Represented major securities firm in parallel N.Y. District Attorney’s Office, SEC and federal grand jury investigations into possible Martin Act violations, securities fraud, tax evasion and money laundering.
Independent consultant retained to review the NYSE’s rules, practices and procedures applicable to floor members.
Selected Publications
“The FCPA and AML Statutes: The Prosecutor’s Combined Weapon of Choice,” Business Crimes Bulletin, December 2011 (co-author)
“Civil and Criminal Enforcement,” Insider Trading Law and Compliance Answer Book (Practising Law Institute) October 2011 (co-author)
“Government Launches FCPA Inquiry into Investments by Sovereign Wealth Funds in U.S. Banks and Private Equity Firms,” Financial Fraud Law Report, July/August 2011 (co-author)
“SEC Extends and Modifies Its No-Action Relief for BDs to Rely on RIAs for Performance of CIP” (Complinet) March 8, 2011 (co-author)
“FinCEN and Regulators Issue Joint Guidance on Obtaining Beneficial Ownership Information, Potentially Expanding Certain Financial Institutions’ USA PATRIOT Act Obligations,” Journal of Investment Compliance, Nov. 22, 2010
“Anti-Money Laundering,” Practitioner’s Guide for Broker-Dealers (Complinet) Nov. 11, 2010 (co-author)
“FinCEN and SEC Sanction Broker-Dealer and Chief Compliance Officer for AML Deficiencies Relating to Foreign Sub-Accounts” (Complinet) Oct. 6, 2010
“Bribery Act 2010,” The Hedge Fund Journal, September 2010 (co-author)
“Clearing Broker Liability and Responsibilities,” Broker Dealer Regulation (Practising Law Institute) May 2010 (co-author)
“Specific Corporate Compliance Challenges by Practice Area: Anti-Money Laundering,” The Corporate Compliance Practice Guide: The Next Generation (Matthew Bender/LexisNexis) 2009 (co-author)
“Representation Prior to Indictment,” Defending Federal Criminal Cases: Attacking the Government's Proof (Law Journal Press) 2009 (co-author)
“Anti-money Laundering Regulation of Broker-Dealers,” Broker Dealer Regulation, Chapter 18, June 2009 (co-author)
“Practice Note: Developing an Effective AML Compliance Program for Hedge Funds” (Complinet) Feb. 12, 2008
“The Foreign Corrupt Practices Act: Recent Cases and Enforcement Trends,” Journal of Investment Compliance, Vol. 8, No. 3, 2007 (co-author)
“Mutual Fund Compliance and the Anti-Money Laundering Regulatory Regime, Part I and II,” The Review of Securities and Commodities Regulation, September 2005 and September 2007
“The Anti-Money Laundering Regime for the Futures Industry,” The Review of Securities and Commodities Regulation, March 2007
“Ask Not For Whom the Bell Tolls, It May Toll For You Next: Intensified Anti-Money Laundering Enforcement Transforms the Regulatory Landscape,” Journal of Investment Compliance, Vol. 6, No.1, Fall 2005
“AML Programs for Financial Institutions Under Section 352 of the USA Patriot Act,” Banking & Financial Services Policy Report, Vol. 21, No. 7, July 2002
“Anti-Money Laundering Provisions of the USA PATRIOT Act of 2001,” CCH, April 2002
“Suitability in Cyberspace,” Securities & Commodities Regulation, Vol. 34, No. 11, June 13, 2001
“Are Self Regulatory Organizations State Actors? Two Recent Cases Take Contrasting Perspectives,” The Journal of Investment Compliance, Vol. 2, No. 1, Summer 2001
“2001: A Money Laundering Space Odyssey,” Securities Industry Association Compliance and Legal Seminar on SIA Website, March 2001
“Did Bankers Trust Alter The Rules?,” New York Law Journal, Corporate Counsel, at S4, Nov. 20, 2000
“How Safe Is The Bank Secrecy Act Safe Harbor?,” Journal of Investment Compliance, Vol. 1, No. 2, Fall 2000
“International Ramifications of U.S. Anti-Money Laundering Policy: Whose Law is the United States Enforcing?,” Journal of International Banking Law, Vol. 15, Issue 4/5, April/May 2000
“Back to the Future: How Recent Events Have Revived the Call for More Stringent Anti-Money Laundering Regulation,” Banking Policy Report, Vol. 19, No. 6, March 20, 2000
“Money Laundering In The Millennium: A Broker-Dealer’s Guide To KYC, SAR & OFAC,” Securities Industry Association Compliance and Legal Division Annual Seminar on SIA Website, March 2000
“The Foreign Corrupt Practices Act and Money Laundering,” Conducting Due Diligence (Practising Law Institute) May 1999
“Money Laundering and Suspicious Activity Reporting: Now What’s a Broker-Dealer To Do?,” Money Laundering Alert, April-July 1999 (published in four parts)
“Money Laundering and Suspicious Activity Reporting,” Securities and Commodities Regulation, Vol. 31, No. 15, Sept. 9, 1998
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Selected Speaking Engagements
“Assessing the Price of Sanctions Violations by U.S. and Non-U.S. Entities, and Individuals: The Agencies’ Approach to Global Investigations, Enforcement and Penalty Calculations,” ACI OFAC Boot Camp, December 2011
“Gifts, Entertainment & Hospitality in High Risk Markets — A Practical Guide on What You Can and Can’t Do,” ACI 26th National Conference on the Foreign Corrupt Practices Act, November 2011
“AML Monitoring,” SEC Roundtable on Microcap Securities, October 2011
“Focus on Securities: Creating Optimal Customer Surveillance Programs” and “Combating Consistent Anti-Money Laundering Challenges: Topical Discussions With Subject Matter Experts,” ACAMS 10th Annual International Anti-Money Laundering Conference, September 2011
“AML Compliance: Hot Topics,” SIFMA Compliance & Legal Society Annual Seminar, March 2011
“Regulatory and Enforcement Roundtable,” ACI AML and OFAC, January 2011
“AML, FCPA and OFAC: The Intersection of Three Key Risk Areas,” SRZ 20th Annual Private Investment Funds Seminar, January 2011
“Fundamentals of FCPA Compliance: The Foreign Corrupt Practices Act Demystified,” ACI 24th Global Conference on the Foreign Corrupt Practices Act, November 2010
“Practical Approach to Combating Consistent Anti-Money Laundering Challenges,” ACAMS 9th Annual International Anti-Money Laundering Conference, September 2010
“AML Compliance — Current Issues,” SIFMA CL 2010 Annual Seminar, May 2010
Moderator, “Regulator Panel — Keeping Current With Regulatory Developments to Ensure Your Institution Remains Compliant,” SIFMA 10th Annual Anti-Money Laundering Conference, March 2010
“FCPA,” Deloitte Third Annual AML Compliance Conference, November 2009
“Enforcement Actions — Monitoring,” ACAMS/Morgan Stanley, October 2009
Moderator, “Regulators Insights: Avoid Penalties and Optimize Your Firm's Defense by Complying With the Latest AML and Fraud Regulations” and “Managing Compliance Requirements for Clearing and Introducing Firms in an Era of Increased Scrutiny and Reduced Resources,” 19th Annual AMLAC & Fraud Forum, October 2009
“Money Laundering and Asset Forfeiture,” ABA’s 23rd Annual National Institute on White Collar Crime, March 2009
SIFMA Annual Anti-Money Laundering Conference, 2001–10
“Q&A Session: 'Ask the Regulators’,” 2nd Annual Anti-Money Laundering & Counter-Terrorist Financing Forum, November 2007
SIFMA Law & Compliance Division Annual Seminar, 1987–2010
SIFMA Compliance & Legal Division Mid-Year Compliance Conference, 2004–06
Co-chair, Institutional Investor’s Anti-Money Laundering and Counter-Terrorist Financing Forum, 2005-06
“AML Guidance for Investment Advisors,” Investment Management Compliance Summit, September 2006
FIA Law and Compliance Seminar, 2002–06
Institute for International Research on Bank Secrecy Act and Anti-Money Laundering, 1996-2005 (Co-chair of program 1999–05)
Co-chair, ICM Conference on Money Laundering, 1999–2002
More
Memberships
Vice-Chair, Board of Directors of National Organization of Italian American Women, 2009 - Present Member, Editorial Board of Complinet, 2009-Present Member, Board of Trustees of Federal Bar Council Foundation, 1997-2003; 2005-08 Member, Fordham Law Alumni Association, Board of Directors, 1997-Present Member, New York City Bar Association, Federal Courts Committee, 1993-94 Division Co-director, ABA Litigation Committee, 1991-92 Chair/Co-chair, ABA Securities Litigation Committee, 1989-91 Chair, Broker/Dealer Sub-Committee of Litigation Committee, 1987-89 Member, ABA White Collar Crime Committee, 1993-Present Secretary, New York Women's Bar Association, 1976-77
Professional Activities Securities Industry and Futures Industry Representative, U.S. Treasury Department Bank Secrecy Act Advisory Group, 1995-2008 Counsel, SIFMA Anti-Money Laundering and Financial Crimes Committee, 2000-Present Member of U.S. Delegation to FATF, October 2002 Chair, Ad Hoc Securities Industry Group on Bank Secrecy Act and Anti-Money Laundering, 1995-2000 U.S. Securities Industry Representative, Financial Action Task Force, 1998
Other Distinctions
International Who's Who of Business Crime Defence Lawyers Ethisphere: Attorneys Who Matter The Best Lawyers in America New York Super Lawyers 2011 Recipient, Highly Commended Award, Emerald Literati Network 2009 Recipient, NOW-NYC Women of Power & Influence Award 2008 Recipient, The Burton Award for Legal Achievement for article titled, "The Foreign Corrupt Practices Act: Recent Cases and Enforcement Trends" 2006 Recipient, Outstanding Paper Award, Emerald Literati Network 1998 Recipient, Director's Medal for Exceptional Service, Financial Crimes Enforcement network of the United States Treasury Department 1988 Recipient, YWCA Women of Achievement Award
Bar Admissions
Court Admissions
- U.S. District Court, Eastern District of New York 1975
- U.S. District Court, Southern District of New York 1975
Education
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Fordham University School of Law, J.D., 1974
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Trinity College, B.A., 1971
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University of Oxford, Honors Program, 1969
Prior Experience
Merrill Lynch Pierce Fenner and Smith Inc., 1983-97 First Vice President and Assistant General Counsel U.S. Attorney’s Office, Southern District of New York, 1977-83 Assistant U.S. Attorney Fordham University School of Law,1982-84, 2003 Adjunct Professor of Law Law Clerk to Honorable Vincent L. Broderick (U.S.D.C., S.D.N.Y.), 1976-77 Martin, Obermaier & Morvillo, 1974–76 Associate
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