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Betty Santangelo

919 Third Avenue
New York, New York 10022
United States of America
P: +1 212.756.2587
E:

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)

More

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

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

  • New York
  • Florida

Court Admissions

  • U.S. District Court, Eastern District of New York 1975
  • U.S. District Court, Southern District of New York 1975

Education

  • Fordham University School of Law, J.D., 1974
  • Trinity College, B.A., 1971
  • 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