Melissa G.R. Goldstein advises banks and other financial institutions on the regulations, rules and related issues governing their investment and banking activities. She has particular expertise with issues arising out of the USA PATRIOT Act and Bank Secrecy Act. Prior to joining SRZ, Melissa was an attorney-advisor with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). At FinCEN, Melissa assisted in the development of regulations governing money services businesses, prepaid access and reporting of foreign bank accounts. Additionally, she was lead counsel on several enforcement actions involving issues such as failure to implement and maintain an adequate BSA/AML compliance program. In recognition of her significant accomplishments during her Treasury career, Melissa received the Secretary’s Meritorious Service Award, which honors individuals whose achievements are substantial and significantly advance the Treasury Department’s mission.

Publications

“Federal Banking Regulators Issue Joint Statement Encouraging Innovation in BSA/AML Compliance,” SRZ Alert, Dec. 5, 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)

NYDFS Issues Guidance to Deter Fraud and Manipulation in Virtual Currency Markets,” SRZ Alert, Feb. 9, 2018 (co-author)

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

“Cyber-SARS: Anti-Money Laundering and Cybersecurity Rules,” The Hedge Fund Journal, January 2017 (co-author)

“FinCEN Advisory on Cybercrime Could Precede Monetary Penalties: Sources,” ACAMS Moneylaundering.com, November 2016 (quoted)

“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

“The Bangladesh Bank Hack and Compliance Programmes,” E-Finance & Payments Law & Policy, May 2016 (co-author); republished in The Hedge Fund Journal, June 2016 

“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 

“CFPB Targets Online Payment Platform in First Enforcement Action on Cybersecurity,” SRZ Alert, March 9, 2016 (co-author); republished in Payments Journal, April 12, 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

“NYDFS Proposes New AML/Sanctions Programs and Annual Certification Requirements for Banks, Money Transmitters and Check Cashers,” SRZ Alert, Dec. 4, 2015 (co-author)

“CFTC’s Position on Bitcoin — and What It Means,” Law360, Sept. 25, 2015 (co-author)

“CFTC Determines That Bitcoin and Other Virtual Currencies Are Commodities,” SRZ Alert, Sept. 18, 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)

“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)

“Virtual Currency Regulation: ‘BitLicense’ Re-Proposed by NYDFS,” SRZ Alert, Feb. 6, 2015 (co-author)

“FinCEN’s Much Anticipated Proposed Rule on Customer Due Diligence Is Finally Here,” Financial Fraud Law Report, November/December 2014 (co-author)

“CFPB Issues Proposed Rule to Provide Additional Federal Consumer Protections for Prepaid Products,” SRZ Alert, Nov. 18, 2014 (co-author)

“CFPB Issues Larger Participants Rule for International Money Transfer Market,” SRZ Alert, Sept. 17, 2014 (co-author)

“Virtual Currency Regulation: Analysis of New York’s Proposal,” Westlaw Journal —Computer & Internet, Sept. 11, 2014 (co-author)

“Virtual Currency Regulation: Summary and Analysis of the New York State Department of Financial Services Proposal,” SRZ Alert, Aug. 15, 2014 (co-author)

“FinCEN’s Much-Anticipated Proposed Rule on Customer Due Diligence Is Finally Here,” SRZ Alert, Aug. 8, 2014 (co-author)

“FinCEN Issues Administrative Rulings Clarifying the Definition of Money Transmitter,” SRZ Alert, May 1, 2014 (co-author)

Speaking Engagements

ILIs Chinese Delegation Seminar on Rights and Defenses of Suspects, New York, October 2018

Payment Processing – A Deep Dive,” Money Transmitter Regulators Association 2017 Annual Conference & Examiners’ School, Savannah, Ga., September 2017

SRZ Investing in Digital Assets and Blockchain Technology Webinar, August 2017

“Concrete Risks — Corruption and Money Laundering in the Acquisition and Construction of Real Estate,” International Association of Young Lawyers Half Year Conference, Chicago, May 2016

“Section 311 and Unintended Consequences,” FIBA 16th Annual AML Compliance Conference, Miami, March 2016

“Are Cuban Cigars Still Contraband? U.S.-Cuban Import-Export Controls Update,” ALM U.S.-Cuba Legal Summit, New York, December 2015

“Prepaid Access,” Money Transmitter Regulators Association 2015 Annual Conference & Examiners’ School, Kansas City, Mo., October 2015

“Bitcoin: A Primer,” ABA Bitcoin and Other Digital Currencies: Emerging Issues in Regulation and Enforcement, Washington, D.C., June 2015

“Clients in Distress — Bankruptcy and Sanctions,” FIA 37th Annual Law & Compliance Division Conference on the Regulation of Futures, Derivatives and OTC Products, Washington, D.C., June 2015

“Regulatory Impact on Prepaid: What’s Hot & What’s Coming,” NACHA Payments 2015, New Orleans, April 2015

“The Latest FinCEN Initiatives: Virtual Currency Initiatives and Administrative Rulings, and a Check Back on the Prepaid Access Rule” and “Ensuring Compliance with the Increasingly Aggressive State Regulatory and Enforcement Framework Governing Emerging Payment Systems, Including Virtual Currencies: An In-Depth Examination of Issues Relating to Money Transmission, Payment Processing, Licensing, and Other Considerations,” ACI 8th National Forum on Emerging Payment Systems Conference, Washington, D.C., September 2014

“An Update on FinCEN Initiatives: Virtual Currency Guidance and the Latest with the Prepaid Access Rule,” ACI 7th National Forum on Balancing Innovation with Consumer Protections in Emerging Payment Systems, San Francisco, March 2014

Distinctions

  • U.S. Department of the Treasury Secretary’s Meritorious Service Award
  • Washington DC Super Lawyers — Rising Star

Prior Experience

  • U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN)
  • U.S. Department of Justice, U.S. Attorney’s Office for the District of Columbia
  • Morgan Stanley & Co. Incorporated, Legal & Compliance, Global Corporate Services