Betty Santangelo focuses her practice on white-collar criminal defense and securities/bank enforcement. A former Assistant U.S. Attorney for the Southern District of New York, she specialized in securities and commodities fraud prosecutions. Her practice includes representing financial institutions (banks, broker-dealers, mutual funds, FCMs, insurance companies, investment advisers, hedge funds and private equity funds), other corporate entities and individuals in matters brought by the U.S. Attorneys’ offices, by various regulatory agencies, including the SEC, the bank regulatory agencies, the CFTC, FINRA, international regulators and state and local prosecutors. Betty also has significant experience conducting internal investigations for these entities. In addition, she has served as an independent consultant in SEC enforcement matters examining both the NYSE and a regional broker-dealer. Prior to joining SRZ, Betty served as First Vice President and Assistant General Counsel for Merrill Lynch, where she managed the firm's securities and criminal regulatory investigations group and represented the firm and its employees in enforcement proceedings before federal and state regulatory agencies, and in criminal matters before U.S. Attorneys' offices and state prosecutors, as well as in foreign jurisdictions. She has also served as Division Director of the ABA Litigation Committee and 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 (Law Journal Press, 2009, 2015), co-authored the “Civil and Criminal Enforcement” chapter of the Insider Trading Law and Compliance Answer Book (Practising Law Institute, 2011–2018) and contributed two chapters in Broker Dealer Regulation (Practising Law Institute, 2009–2010, 2014–2017). Betty is recognized as a leading lawyer by The Legal 500 US, The Best Lawyers in America, Ethisphere: Attorneys Who Matter, Expert Guide to the World’s Leading White Collar Crime Lawyers, Expert Guide to the World’s Leading Women in Business Law, Who's Who Legal: Business Crime Defence and New York Super Lawyers. She was also presented with the New York Chapter of the National Organization for Women's 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 also 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 her 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. Betty also is a founding member of and has served as counsel to the Securities Industry and Financial Markets Association’s (SIFMA) Anti-Money Laundering and Financial Crimes Committee. In 2014, she was honored by SIFMA for her extraordinary contributions to the committee and recognized for her dedication to improving industry compliance. 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, she 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. Betty is a former adjunct professor at Fordham Law School, where she taught a course on money laundering and founded Fordham Law Women to raise awareness of the issues faced by women in the law school community. In 2019, Fordham Law established the Betty Santangelo Award to recognize female alumnae working to advance the careers of women in the legal industry. Betty is a much sought-after speaker on corporate compliance, anti-money laundering/OFAC/FCPA, white-collar criminal and securities law issues, including at SIFMA, the FIA, ACAMS, the ABA/ABA AML conference and FIBA. 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. She is a recipient of the YWCA Woman of Achievement award, as well as other awards.

Representations

Involved in numerous representations of large banks and broker-dealers in connection with possible AML/BSA violations before the SEC, FINRA, the bank regulators and FinCEN.

Conducting internal investigation into possible money laundering and foreign tax fraud by foreign institutional client of U.S. commercial bank.

Representation of global financial institution in international money laundering investigation.

Representation of 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.

Representation of foreign banks before OCC in connection with negotiation of settlement agreement and examination by SEC.

Advise large private equity funds and private investment funds in connection with establishing of AML/sanctions programs.

Publications

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

“Federal Banking Regulators Update Guidance on Model Risk Management Practices for AML and Sanctions Compliance,” SRZ Alert, June 10, 2021

Securities Enforcement Quarterly, SRZ Publication, April 2021

“FinCEN Commences Rulemaking Process for Implementation of Corporate Transparency Act Requiring Disclosure of Beneficial Ownership Information,” SRZ Alert, April 26, 2021; republished in the Harvard Law School Forum on Corporate Governance, May 11, 2021

“Broker-Dealers and Mutual Funds: Increased Regulatory Focus on Suspicious Activity Monitoring and Reporting Requirements,” SRZ Alert, April 1, 2021

“US Sanctions on Chinese Company Securities: Further Developments,” SRZ Alert, Jan. 19, 2021

“Passage of Anti-Money Laundering Act of 2020 Includes Comprehensive BSA/AML Reform Measures,” SRZ Alert, Jan. 7, 2021

“OFAC Provides Guidance on Trading Ban in Chinese Companies,” SRZ Alert, Dec. 31, 2020

“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

“White House Bans Trading in 31 Chinese Companies,” SRZ Alert, Nov. 13, 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; republished in The Banking Law Journal, February 2021

“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)

Speaking Engagements

“Confusion Worse Confounded: AML in the Capital Markets,” SIFMA Anti-Money Laundering & Financial Crimes Conference, New York, February 2019

“Hot Topics: AML, Cybersecurity, Privacy, GDPR,” FIA Law & Compliance Division 40th Annual Law & Compliance Division Conference, Washington DC, May 2018

“Shells and Pillars: Are You Ready?,” SIFMA Anti-Money Laundering & Financial Crimes Conference, New York, February 2018

“DFS, State, and OFAC Officials Weigh-In on Regulatory Hot Buttons Governing the Insurance and Reinsurance Industries,” 8th Annual Forum on AML & OFAC Compliance for the Insurance Industry, January 2018

“Developments in AML – What’s New?,” FIA Law & Compliance Division 39th Annual Law & Compliance Conference on the Regulation of Futures, Derivatives and OTC Products, May 2017

“Crisis Management and Reactions to Breaking Events,” SIFMA 17th Annual Anti-Money Laundering & Financial Crimes Conference, February 2017

“Regulatory and Enforcement Roundtable: Perspectives from Federal and State Agencies that Govern the Insurance and Reinsurance Industries,” ACI 7th Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2017

“What to Do When You Suspect a Violation? Tips for Internal Investigations and Determining the Value of a Voluntary Self-Disclosure,” ACI 7th Annual New York Forum on Economic Sanctions, December 2016

“A Financial Institution Under Criminal Investigation – Strategic Issues,” Deloitte Tenth Annual AML Conference, October 2016

“Sanctioning Compliance Officers: External and Internal Sanctions on Compliance Officers,” NYU Law Compliance: New Risks, Challenges, and Approaches Conference, October 2016

“Customer Due Diligence in a Global AML Environment,” SIFMA 16th Annual Anti-Money Laundering & Financial Crimes Conference, April 2016

Co-Moderator, “Regulatory and Enforcement Roundtable: Perspectives from OFAC, the Department of State, the DOJ, and Other Federal and State Agencies That Govern the Insurance and Reinsurance Industries,” ACI 6th Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2016

“Meeting Government’s Expectations: How Much Is Enough Due Diligence to Protect Your Organization?,” ACI 6th Annual Economic Sanctions Bootcamp, December 2015

“AML Compliance: Hot Topics,” SIFMA Compliance & Legal Society Annual Seminar, March 2015

“Compliance Officers and Personal Liability: Are You At Risk?,” ACAMS Webinar, March 2015

“Lessons Learned from Enforcement,” SIFMA 15th Annual Anti-Money Laundering & Financial Crimes Conference, February 2015

Co-Moderator, “Regulatory and Enforcement Roundtable: Perspectives from the Department of State, the Office of the New York State Attorney General, the Secret Service, and Other Federal and State Agencies That Govern the Insurance and Reinsurance Industries,” ACI 5th Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2015

“Know Your Product: Money Laundering Risks in New and Complex Products,” ABA Money Laundering Enforcement Conference, November 2014

“Current Regulatory and International Issues,” FIA Law & Compliance Regulatory Roundup: A Mid-Year Review for Chicago Members, September 2014

“AML Compliance: Hot Topics,” SIFMA Compliance and Legal Society Annual Seminar, April 2014

Moderator, “AML and Beyond: The Intersection of AML, Anti-Corruption and Sanctions,” SIFMA 14th Annual Anti-Money Laundering and Financial Crimes Conference, January 2014

Co-Moderator, “Regulatory and Enforcement Roundtable: Perspectives from the Department of State, the DOJ, the U.S. Attorney’s Office, the Office of the New York State Attorney General, and Other Federal and State Agencies That Govern the Insurance Industry,” ACI 4th Annual Forum on AML & OFAC Compliance for the Insurance Industry, January 2014

Co-Chair, ACI 4th Economic Sanctions Boot Camp, December 2013

“AML Compliance — Hot Topics,” SIFMA Compliance and Legal Society Annual Seminar, March 2013

Moderator, “Significant Sanctions Enforcement Actions and Other Financial Crime Developments,” SIFMA 13th Annual Anti-Money Laundering & Financial Crimes Conference, February 2013

“Beneficial Ownership: Will A Risk-Based Approach Survive?” and “Broker Dealer & Wealth Management,” FIBA 13th Annual Anti-Money Laundering Compliance Conference, February 2013

Moderator, “Conducting Effective Internal Investigations into Potential Money Laundering, Fraud, Sanctions Violations, or FCPA Violations,” ACI 3rd Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2013

“The Aftermath of the $619 Million ING Case, and What It Says About Sanctions Penalty Calculations: Mitigating and Aggravating Factors for Financial Institutions, Non-Regulated Entities and Individuals,” ACI OFAC Boot Camp, December 2012

“Regulatory Investigations,” PLI Bet the Company Litigation, September 2012

“Enforcement Against Regulated Financial Institutions,” ACI 5th Advanced Forum on OFAC Enforcement and Compliance, April 2012

“Securities Focus: Reverse Mergers, Penny Stock and Micro-Cap Securities Fraud — What are the AML Risks and Regulatory Expectations?,” ACAMS 17th Annual International Anti-Money Laundering Conference, March 2012

“AML Compliance — Hot Topics,” SIFMA 2012 Compliance and Legal Society Annual Seminar, March 2012

“Ten Years After 9/11: A Retrospective On How We Got Here” and “‘Who's On First?’ – Managing the Allocation of AML Responsibilities in a New Regulatory Environment,” SIFMA 12th Annual Anti-Money Laundering and Financial Crimes Conference, February 2012

“Conducting Internal Investigations into Potential Money Laundering, Sanctions Violations, or FCPA Violations,” ACI 2nd Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2012

“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

Memberships

  • Member, Board of Directors of National Organization of Italian American Women, 2009–Present;
    • Chair, 2012–2014
    • Chair Elect, 2012 
    • Vice Chair, 2009–2011
  • Former Member, Editorial Board of Complinet
  • Member, Board of Trustees of Federal Bar Council Foundation, 1997–2003; 2005–2008; 2012–2019
  • Member, Fordham Law Alumni Association, Board of Directors, 1997–Present
  • Member, New York City Bar Association, Federal Courts Committee, 1993–1994
  • Division Co-director, ABA Litigation Committee, 1991–1992
  • Chair/Co-chair, ABA Securities Litigation Committee, 1989–1991
  • Chair, Broker/Dealer Sub-Committee of Litigation Committee, 1987–1989
  • Member, ABA White Collar Crime Committee, 1993–Present
  • Secretary, New York Women's Bar Association, 1976–1977
  • Founder, Fordham Law Women, 1972
  • Professional Activities
  • Securities Industry and Futures Industry Representative, U.S. Treasury Department Bank Secrecy Act Advisory Group, 1995–2008
  • Member, SIFMA Anti-Money Laundering and Financial Crimes Committee, 2014–Present; Counsel, 2000–2014
  • 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

Distinctions

  • The Best Lawyers in America
  • Ethisphere: Attorneys Who Matter
  • Expert Guide to the World’s Leading White Collar Crime Lawyers
  • Expert Guide to the World’s Leading Women in Business Law (White Collar Crime)
  • Who's Who Legal: Business Crime Defence
  • The Legal 500 US
  • New York Super Lawyers
    • Top Women Attorneys in the New York Metro Area
  • 2014 Recipient, SIFMA Award in recognition of extraordinary contributions to the Anti-Money Laundering and Financial Crimes Committee
  • 2011 Recipient, Highly Commended Award, Emerald Literati Network
  • 2009 Recipient, NOW-NYC Women of Power & Influence Award
  • 2008 Recipient, Burton Award for Distinguished Legal Writing 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

Prior Experience

  • Merrill Lynch Pierce Fenner and Smith Inc., 1983-1997 
    • First Vice President and Assistant General Counsel
  • U.S. Attorney’s Office, Southern District of New York, 1977-1983
    • Assistant U.S. Attorney
  • Fordham University School of Law, 1982-1984, 2003
    • Adjunct Professor of Law
  • Law Clerk to Honorable Vincent L. Broderick (U.S.D.C., S.D.N.Y.), 1976-1977
  • Martin, Obermaier & Morvillo, 1974–1976
    • Associate