Books/Treatises
“Civil and Criminal Enforcement,” Insider Trading Law and Compliance Answer Book (Practising Law Institute), 2011–2020
Private Equity Funds: Formation and Operation (Practising Law Institute) (contributor)
Hedge Funds: Formation, Operation and Regulation (ALM Law Journal Press) (contributor)
“Representation Prior to Indictment,” Defending Federal Criminal Cases: Attacking the Government's Proof (Law Journal Press), 2009 and 2015 (co-author)
“Anti-Money Laundering Regulations Applicable to Broker-Dealers,” Broker Dealer Regulation (Practising Law Institute), September 2014
“Anti-Money Laundering,” Practitioner’s Guide for Broker-Dealers (Complinet), Nov. 11, 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)
“Anti-money Laundering Regulation of Broker-Dealers,” Broker Dealer Regulation, Chapter 18, June 2009 (co-author)
“Mutual Fund Compliance and the Anti-Money Laundering Regulatory Regime, Part I and II,” The Review of Securities & Commodities Regulation, September 2005 and September 2007
“The Anti-Money Laundering Regime for the Futures Industry,” The Review of Securities & Commodities Regulation, March 2007
“Suitability in Cyberspace,” Securities & Commodities Regulation, Vol. 34, No. 11, June 13, 2001
“The Foreign Corrupt Practices Act and Money Laundering,” Conducting Due Diligence (Practising Law Institute), May 1999
“Money Laundering and Suspicious Activity Reporting,” Securities and Commodities Regulation, Vol. 31, No. 15, Sept. 9, 1998
Articles
“Passage of Anti-Money Laundering Act of 2020 Includes Comprehensive BSA/AML Reform Measures,” SRZ Alert, Jan. 7, 2021
“FinCEN Releases Notice of Proposed Rulemaking and FAQs Concerning Convertible Virtual Currency and Legal Tender Digital Asset Transactions,” SRZ Alert, Dec. 23, 2020
“SEC Staff Bulletin Highlights AML Risks Associated with Low-Priced Securities Trading in Omnibus Accounts,” SRZ Alert, Dec. 14, 2020
“Treasury Issues Advisories Related to Ransomware Attacks,” SRZ Alert, Dec. 1, 2020
“AML Managers Question FinCEN’s New Effectiveness Test,” FinOps Report, Oct. 7, 2020 (quoted)
“FinCEN and Banking Agencies Provide Clarification on PEP Screening Best Practices,” SRZ Alert, Oct. 5, 2020
“AML Update: FinCEN Issues First-Ever Enforcement Guidelines and Federal Banking Agencies Update Enforcement Guidance,” SRZ Alert, Sept. 2, 2020
“Sanctions Update: OFAC Regulations, Advisories and Enforcement Actions: November 2019 through July 2020,” SRZ Alert, August 7, 2020; republished in The Hedge Fund Journal, September 2020
“Sanctions Update: US Sanctions Compliance During COVID-19,” SRZ Alert, April 24, 2020
“US Government Continues to Penalize Unauthorized Disclosures of Suspicious Activity Reports,” SRZ Alert, Feb. 24, 2020
“Mitigating OFAC Risks in Mergers and Acquisitions,” SRZ Alert, Feb. 3, 2020; republished in Thomson Reuters Westlaw Journal Bankruptcy, March 24, 2020
“Sanctions Update: DOJ Revises Voluntary Self-Disclosure Policy for Export Control and Sanctions Violations,” SRZ Alert, Jan. 2, 2020
“OFAC Expands Reporting Obligations and Highlights Importance of Cooperation,” SRZ Alert, Nov. 21, 2019; republished in The Hedge Fund Journal, February 2020
“Sanctions Update: Iran, Venezuela, Ukraine, Nicaragua and Cuba,” SRZ Alert, Oct. 11, 2019 (co-author)
“Federal Banking Regulators Issue Joint Statement on BSA/AML Compliance Program Examinations,” SRZ Alert, August 1, 2019 (co-author)
“OFAC Update: A Framework for Compliance and Recent Settlements,” SRZ Alert, July 12, 2019 (co-author); republished in The Hedge Fund Journal, August 2019
“FinCEN Assesses Civil Money Penalty Against P2P Currency Exchanger for BSA Violations,” SRZ Alert, April 26, 2019 (co-author)
“Sanctions Update: Venezuela,” SRZ Alert, April 4, 2019 (co-author)
“Sanctions Update: OFAC Sanctions Venezuela’s State-Owned Oil Company,” SRZ Alert, Feb. 8, 2019 (co-author)
“Federal Banking Regulators Issue Joint Statement Encouraging Innovation in BSA/AML Compliance,” SRZ Alert, Dec. 5, 2018 (co-author)
“Sanctions, Sanctions and More Sanctions!” The Hedge Fund Journal, December 2018 (co-author)
“Sanctions Update: Iran, Venezuela and Russia,” SRZ Alert, Nov. 13, 2018 (co-author)
“Arrest of FinCEN Employee for Unlawful Disclosure of SARs and SAR Information,” SRZ Alert, Oct. 19, 2018 (co-author)
“FinCEN and Federal Banking Agencies Issue Statement on Pooling Resources for BSA Compliance,” SRZ Alert, Oct. 5, 2018 (co-author)
“Sanctions Update: Iran, Global Magnitsky and Sudan,” SRZ Alert, July 24, 2018 (co-author)
“Venezuela Sanctions Complicate Compliance for Companies,” Law360, June 25, 2018 (co-author)
“New Licenses May Ease Ukraine, Russia Business Wind-Downs,” Law360, June 19, 2018 (co-author)
“Sanctions Update: Venezuela and Ukraine/Russia,” SRZ Alert, June 4, 2018 (co-author)
“OFAC Focuses on Oligarchs, Adds Sanctions on Russian Persons and Entities,” SRZ Alert, April 26, 2018 (co-author)
“NYDFS Issues Guidance to Deter Fraud and Manipulation in Virtual Currency Markets,” SRZ Alert, Feb. 9, 2018 (co-author)
“Treasury Identifies Russian Political Figures and Oligarchs,” SRZ Alert, Feb. 1, 2018 (co-author)
“Sanctions and AML Update: North Korea and Venezuela,” SRZ Alert, Sept. 27, 2017 (co-author); republished in The Hedge Fund Journal, October 2017
“Sanctions Update: U.S. Imposes Immediate Restrictions Relating to Venezuelan Securities,” SRZ Alert, Aug. 28, 2017 (co-author)
“Sanctions Update: Russia, Iran, North Korea and Venezuela,” SRZ Alert, Aug. 2, 2017 (co-author); republished in The Hedge Fund Journal, August 2017
“FinCEN Issues Assessment Against Virtual Currency Exchange — the First Enforcement Action Against a Foreign-Located Money Services Business,” SRZ Alert, July 27, 2017 (co-author); republished in PaymentsJournal, Aug. 14, 2017
“FinCEN Renews GTOs Targeting Real Estate Transactions,” SRZ Alert, March 1, 2017 (co-author)
“FinCEN Issues Suspicious Activity Report Guidance Concerning Cybersecurity,” SRZ Alert, Nov. 1, 2016 (co-author)
“DOJ and OFAC Take Enforcement Action Against Canadian Payment Processor,” SRZ Alert, Sept. 23, 2016 (co-author); republished in Payments Journal, Oct. 17, 2016
“NYDFS Issues AML/Sanctions Programs and Annual Certification Requirements for Banks, Money Transmitters and Check Cashers,” SRZ Alert, July 6, 2016 (co-author); republished in Westlaw Journal — Bank & Lender Liability, Sept. 19, 2016
“US Eases Sanctions on Burma,” SRZ Alert, May 31, 2016 (co-author)
“Highlights of FinCEN’s Long-Awaited Customer Due Diligence Final Rule,” SRZ Alert, May 11, 2016 (co-author); republished in The Hedge Fund Journal, June 2016
“OFAC and BIS Amend Cuba Sanctions Regulations,” SRZ Alert, Feb. 1, 2016 (co-author)
“New AML Regulatory Initiative Targets Real Estate Industry,” SRZ Alert, Jan. 21, 2016 (co-author); republished in Westlaw Journal – White-Collar Crime, March 2016
“‘Implementation Day’ Marks Rollback of Significant Nuclear-Related Sanctions on Iran,” SRZ Alert, Jan. 20, 2016 (co-author); republished in Business Crimes Bulletin, June 2016
“NYDFS Proposes New AML/Sanctions Programs and Annual Certification Requirements for Banks, Money Transmitters and Check Cashers,” SRZ Alert, Dec. 4, 2015 (co-author)
“The New AML Rules: Implications for Private Fund Managers,” SRZ Alert, Sept. 8, 2015 (co-author); republished in The Hedge Fund Journal, Sept. 24, 2015
“Federal and State Regulators Target Compliance Officers — Part II,” The Banking Law Journal, September 2015 (co-author)
“Federal and State Regulators Target Compliance Officers — Part I,” The Banking Law Journal, July/August 2015 (co-author)
“BHP Billiton Settles with SEC for $25 Million for Providing Foreign Officials with Luxury Travel to Olympics,” SRZ Alert, May 21, 2015 (co-author)
“PayPal Settlement Highlights OFAC Risks for Money Services Businesses,” SRZ Alert, March 27, 2015 (co-author)
“Federal and State Regulators Target Compliance Officers,” SRZ Alert, Feb. 20, 2015 (co-author)
“Sanctions Update: Crimea,” SRZ Alert, Feb. 5, 2015 (co-author); republished in Westlaw Journal – Securities Litigation & Regulation, March 5, 2015
“FinCEN’s Much Anticipated Proposed Rule on Customer Due Diligence Is Finally Here,” Financial Fraud Law Report, November/December 2014 (co-author)
“Sanctions Update: Sectoral Sanctions Against Russia Escalate,” SRZ Alert, Sept. 18, 2014 (co-author); republished in Westlaw Journal – Securities Litigation & Regulation, Oct. 16, 2014
“FinCEN’s Much-Anticipated Proposed Rule on Customer Due Diligence Is Finally Here,” SRZ Alert, Aug. 8, 2014 (co-author)
SRZ Insider Trading Developments Newsletter, Summer 2014 (contributor)
“Threatened Sectoral Sanctions Against Russia Become Reality,” SRZ Alert, July 30, 2014 (co-author)
“Escalating U.S.–Russia Tensions Lead to New Sanctions, Heightened AML Risks,” SRZ Alert, April 4, 2014 (co-author)
“Funds Face New Sanctions, AML Risks in Wake of Escalating U.S.–Russia Tensions,” SRZ Alert, April 4, 2014 (co-author)
“FinCEN Issues Final Rules Relating to Money Services Business (MSB) Definitions,” Journal of Investment Compliance, April 2012 (co-author)
“Recent FCPA Developments Highlight Risk of Individual Liability,” Financial Fraud Law Report, March 2012 (co-author)
“The FCPA and AML Statutes: Prosecutors Increasingly Combining Charges, to Great Effect,” Business Crimes Bulletin, January 2012 (co-author)
“The FCPA and AML Statutes: The Prosecutor’s Combined Weapon of Choice,” Business Crimes Bulletin, December 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
“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)
“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)
“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
“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
“Money Laundering and Suspicious Activity Reporting: Now What’s a Broker-Dealer To Do?,” Money Laundering Alert, April-July 1999 (published in four parts)