Seetha Ramachandran is widely recognized as a leading expert in anti-money laundering (AML), Bank Secrecy Act (BSA), economic sanctions and asset forfeiture matters. She represents banks, broker-dealers, hedge funds, private equity funds, online payment companies, and individual executives and officers, in high stakes and sensitive matters. Her practice focuses on internal investigations, regulatory enforcement defense, white-collar criminal defense and compliance counseling. Seetha served as a federal prosecutor for nearly 10 years, including as Deputy Chief in the Asset Forfeiture and Money Laundering Section (AFMLS), Criminal Division, U.S. Department of Justice. There she was the first head of DOJ’s Money Laundering & Bank Integrity Unit — DOJ’s criminal litigation unit responsible for AML and sanctions enforcement. She spearheaded and supervised DOJ’s first major AML prosecutions, including those of HSBC, MoneyGram, Standard Chartered Bank and ING. As a Deputy Chief at AFMLS, Seetha oversaw all of the Criminal Division’s AML cases, including those involving national and foreign banks, casinos, online payment companies, virtual currencies and individual defendants. During her tenure at DOJ, Seetha coordinated closely with state and federal banking regulators, including FinCEN, the OCC and the New York State Department of Financial Services, giving her deep experience with how these agencies work together, especially in matters involving civil and criminal liability. Her work developing and charging criminal cases under the Bank Secrecy Act (BSA) formed the model for AML enforcement that regulators and prosecutors follow today, and she uses her extensive first-hand experience to help clients navigate the complex expectations of regulators, examination teams, and law enforcement agencies in this area.
In addition to her subject matter expertise, Seetha is an experienced trial and appellate lawyer, having conducted 10 criminal jury trials, argued 10 appeals before the U.S. Court of Appeals for the Second Circuit, and handled ancillary civil proceedings in forfeiture cases. Prior to her appointment at AFMLS, Seetha served as an Assistant U.S. Attorney for the Southern District of New York for nearly six years, in the Complex Frauds, Major Crimes and Asset Forfeiture units. As an Assistant U.S. Attorney, she investigated and prosecuted white-collar cases involving a wide range of financial crimes, including bank fraud, mail and wire fraud, tax fraud, money laundering, stolen art and cultural property, and civil and criminal forfeiture cases. Seetha is an accomplished public speaker and a prolific writer, on topics that include enforcement trends in the financial services industry, OFAC sanctions, effective AML programs and asset forfeiture.
- Representing broker-dealer in multiple criminal and regulatory investigations by the DOJ, New York Attorney General and the CFTC.
- Represented foreign hedge fund and its CEO in SEC proceedings and DOJ investigation relating to cybercrime and insider trading, and successfully persuaded foreign government to unfreeze bank accounts.
- Represented sports broadcasting company on various commercial issues arising from an indictment of FIFA members for bribery.
- Conducted an internal investigation for loan and finance company, following an examination by the Federal Reserve Bank of New York. Recommended remedial measures that prevented any further regulatory action based on the underlying conduct.
- Representing auction house in declaratory judgment action relating to cultural property.
- Conducted internal investigation for broker-dealer, in connection with foreign exchange trading, and successfully settled all outstanding civil liability.
- Conducted internal investigation for private investment manager, in connection with FCPA issues and conflicts of interest.
- Representing multiple individual defendants in connection with criminal forfeiture and restitution issues, including the pretrial restraint of attorney’s fees.
- Representing online publisher in multiple criminal and civil forfeiture proceedings.
- Representing victims in forfeiture and restitution proceedings.
- Advising various clients, including hedge funds, investment advisers, private equity firms, portfolio companies, banks, broker-dealers and payment companies, on AML, OFAC and FCPA issues (including OFAC license applications and voluntary self-disclosures, development and review of AML policies, and transactional advice).
- Providing pro bono advice to international health organization on various OFAC compliance matters.
- Represented non-profit public interest organization pro bono in connection with congressional subpoena.
- Advised SIFMA’s Asset Management Group in connection with comment letter on FinCEN’s 2015 proposed AML rule for registered investment advisers.
“Sanctions Update: OFAC Sanctions Venezuela’s State-Owned Oil Company,” SRZ Alert, Feb. 8, 2019 (co-author)
“Sanctions Update: Iran, Venezuela and Russia,” SRZ Alert, Nov. 13, 2018 (co-author); republished in The Hedge Fund Journal, December 2018
Hedge Funds: Formation, Operation and Regulation (ALM Law Journal Press), 2018 (contributor)
“Arrest of FinCEN Employee for Unlawful Disclosure of SARs and SAR Information,” SRZ Alert, Oct. 19, 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)
“What New Russia Trade Sanctions Mean for US Companies and Investors,” The National Law Journal, May 2, 2018 (quoted)
“Lessons Private Fund Managers Can Learn From US Bancorp’s Settlement of AML Violations,” The Hedge Fund Law Report, April 26, 2018 (quoted)
“OFAC Focuses on Oligarchs, Adds Sanctions on Russian Persons and Entities,” SRZ Alert, April 26, 2018 (co-author)
“Treasury Identifies Russian Political Figures and Oligarchs,” SRZ Alert, Feb. 1, 2018 (co-author)
“The Growing Interest in Cryptocurrencies: Q&A with SRZ's Blockchain Technology & Digital Assets Group,” The Hedge Fund Journal, December 2017 (interview)
“Sanctions and AML Update: North Korea and Venezuela,” SRZ Alert, Sept. 27, 2017 (co-author); republished in The Hedge Fund Journal, October 2017
“Should Lawyers be Required to Investigate Their Own Clients?” Financier Worldwide, September 2017 (co-author)
“Sanctions Update: U.S. Imposes Immediate Restrictions Relating to Venezuelan Securities,” SRZ Alert, Aug. 28, 2017 (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
“Sanctions Update: Russia, Iran, North Korea and Venezuela,” SRZ Alert, Aug. 2, 2017 (co-author); republished in The Hedge Fund Journal, August 2017
“New Anti-Terrorism Chief to Tackle Differing US-EU Regulations,” Bloomberg BNA, Aug. 2, 2017 (quoted)
“FORUM: Tackling Fraud and Money Laundering Within Financial Institutions,” Financier Worldwide, July 2017 (interview)
“FinCEN Renews GTOs Targeting Real Estate Transactions,” SRZ Alert, March 1, 2017 (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)
“OFAC and BIS Amend Cuba Sanctions Regulations,” SRZ Alert, Feb. 1, 2016 (co-author)
“Reviewing CFTC Regulation AT Proposals,” The Hedge Fund Journal, January 2016 (quoted)
“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
“The CFTC Brings (and Settles) Its First Insider-Trading Case: Implications for All Private Fund Managers,” SRZ Alert, Dec. 15, 2015 (co-author); republished in The Hedge Fund Journal, January 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)
“Treasury Proposes Money-Laundering Controls for Investment Advisers,” The Wall Street Journal — Risk & Compliance Journal, Aug. 25, 2015 (quoted)
“Federal and State Regulators Target Compliance Officers — Part I,” The Banking Law Journal, July/August 2015 (co-author)
“In Depth: Ripple Labs — from Silicon Valley to the Wild West,” PaymentsCompliance, May 13, 2015 (interview)
“CFPB Sues Payment Processors for Failing to Detect Fraud Committed by Others,” SRZ Alert, April 10, 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)
“The Interplay Between Forfeiture and Restitution in Complex Multi-Victim White Collar Cases,” Federal Sentencing Reporter, October 2013 (co-author)
“Focus on NY Sanctions: Increased Focus on AML/Sanctions and Due Diligence,” ACI 9th Annual New York Forum on Economic Sanctions, New York, December 2018
“Economic Sanctions Regulatory and Enforcement Priorities for the Year Ahead,” ACI Financial Crime Executive Roundtable, New York, September 2018
“An In-Depth Exploration of Successful Blockchain Applications: Finding Solutions and Overcoming Legal and Compliance Hurdles,” ACI Legal, Regulatory and Compliance Forum on FinTech and Emerging Payment Systems Conference, New York, April 2018
“Transaction Laundering: The Threat and Risk in Online Payments,” Innoxcell White Collar Crime Tech, New York, March 2018
“Cyber-Related Events and Suspicious Activity Reporting,” SIFMA Anti-Money Laundering & Financial Crimes Conference, New York, February 2018
“Enforcement,” SRZ 27th Annual Private Investment Funds Seminar, New York, January 2018
“Iran Sanctions Complexities: Navigating Both EU and U.S. Rules When Doing Business in Iran Amid Uncertain Times,” American Conference Institute 8th Annual Forum on Economic Sanctions, December 2017
SRZ Insider’s Guide to Government Investigations: Winning Strategies for Investment Funds, June 2017
“Anti-Money Laundering for Advisers,” ACA Compliance Group Spring 2017 Compliance Conference, May 2017
SRZ Insider's Guide to Government Investigations: Winning Strategies for Investment Funds, April 2017
“Developing, Implementing and Maintaining AML, Sanctions and Fraud Deterrence Programs,” ACI Payment Systems and FinTech: Regulatory & Compliance Conference, April 2017
Columbia University School of Law How to Track an Oligarch, and What to do When You Find One?, March 2017
“Regulatory Focus: AML, Cybersecurity and FCPA,” SRZ 26th Annual Private Investment Funds Seminar, January 2017
“Status Update and Q&A on New York State Sanctions: How New Regulations and Certification Requirements Affect Compliance Initiatives amidst a Coordinated State/Federal Enforcement Landscape,” ACI 7th Annual New York Forum on Economic Sanctions, December 2016
SRZ Managing Attorney-Client Privilege: A Workshop for Private Fund GCs and CCOs, July 2016
“Strengthening Compliance Amid Changing AML/OFAC Rules,” ACI 3rd Summit on FCPA, AML & OFAC Risks for Private Equity and Hedge Funds, April 2016
“The New Anti-Money Laundering Rule,” SRZ 25th Annual Private Investment Funds Seminar, January 2016
“Regulation AT: Overview and Implications,” SRZ Webinar, December 2015
“Understanding Your 2015 Sanctions Risk Landscape in Response to Increased Global Enforcement,” ACI 6th Annual Economic Sanctions Bootcamp, December 2015
“Breaking Barriers: Diversifying the White Collar Bar,” National Asian Pacific American Bar Association Convention, November 2015
“Spotlight on Women Power Players in Government: Shaping the Future of Financial Services Law,” ACI Conference on Women Leaders in Financial Services Industry Law, June 2015
“Views and Practical Guidance from Speakers from the Federal Government: Perspectives on the Evolving Heightened Federal Regulatory and Enforcement Paradigm Affecting the Evaluation and Offering of Emerging Payment Systems and Services,” ACI 9th National Advanced Forum on Emerging Payment Systems, March 2015
“Regulatory Outlook: Exams, Enforcement and AIFMD,” SRZ 24th Annual Private Investment Funds Seminar, January 2015
“Global Enforcement Year in Review — Global Investigations of Financial Institutions Continue to Make Headlines and Generate Huge Penalties: Where Are You Vulnerable?,” ACI 5th Annual Economic Sanctions Bootcamp, December 2014
“The Developing Federal Legal and Regulatory Framework Governing the Digital and Virtual Landscape and How These Alternative Currencies Fit into the Baskets That Give Federal Authorities Their Jurisdiction to Regulate: The Impact of Regulation Thus Far, Where Is the Need (or Not) for Further Regulation, Gray Areas, Scrutiny and Concerns over Misuse, Warnings / Statements / Determinations Issued, and Beyond,” ACI 2nd National Forum on Virtual & Digital Currency and Payment Systems, November 2014
ABA and Navigant Law & Innovation Speaker Series — Digital Currency, November 2014
“Deputizing Banks: Anti-Money Laundering Enforcement and Your Banker as Watchdog – or Criminal Defendant,” PACDL White Collar Practice Seminar, November 2014
“The Developing Federal Legal and Regulatory Framework Governing the Digital and Virtual Currency Landscape: The Impact of Regulation Thus Far, and the Need (or Not) for Further Regulation,” ACI National Forum on Virtual & Digital Currency and Payment Systems, June 2014
“The Financial Crisis: Five Years Later,” South Asian Bar Association Annual Conference, June 2014
“Understanding and Managing Risk in the Emerging Payments Area,” Buckley Sandler LLP Webinar, May 2014
“Federal Regulatory and Enforcement Roundtable and Industry Responses: Insight on Latest Initiatives, Compliance, Obligations, and Fraud and Risk Schemes,” ACI Ninth National Forum on Prepaid Card Compliance, January 2014
“Virtual Currency: Viability, Compliance & Direction,” Wells Fargo Seminar, January 2014
“Regulatory and Enforcement Roundtable: Perspectives from the Federal and State Agencies that Govern the Insurance Industry,” Annual Forum on AML/OFAC Compliance for Insurance, January 2014
“Debating New and Emerging Regulatory and Enforcement Priorities Within the Prepaid and Emerging Payments Industry,” Prepaid, Mobile & Emerging Payment Systems Conference, November 2013
“Views from the Federal Government: Perspectives from FDIC, the Fed, Treasury, FTC, DOJ, OCC, and OFAC on New and Emerging Payment Systems and the Evolving Federal Regulatory and Enforcement Paradigm,” National Forum on Emerging Payment Systems Conference, September 2013
ACI Advanced Forum on International & Cross Border Payments, June 2013
“Best Practices for Ensuring you are Running a Thoroughly Compliant Program in the Current and Impending Regulatory Environment,” Network Branded Prepaid Card Association’s Power of Prepaid Conference, June 2013
ACI Economic Sanctions Enforcement and Compliance, June 2013
ACI Advanced Forum on International & Cross Border Payments, November 2012
“Enforcement Actions,” Deloitte AML Compliance Conference, October 2012
Federal Reserve Bank Gulf Coast AML Forum, September 2012
Federal Reserve Bank HIFCA Financial Symposium, June 2012
“White Collar Crime, Business Bankruptcy, and the Problem of Asset Forfeiture and Distribution,” Golden Gate Law School, November 2011
“Enforcement Actions,” Deloitte AML Compliance Conference, October 2011
“Minority Women Litigators: Experiences in the Courtroom and Beyond,” New York City Bar Association, October 2011
International Conference on Financial Crime and Terrorism Financing, Kuala Lumpur, Malaysia, September 2011
“Finding the Money: How Experts Trace Assets,” New York State Society of CPAs, June 2011
- The Legal 500 US
- Deputy Chief, Asset Forfeiture & Money Laundering Section, Criminal Division, U.S. Department of Justice, 2011-2014
- Assistant United States Attorney, U.S. Attorney’s Office, Southern District of New York, 2005-2011
- Richards Spears Kibbe & Orbe, 2003-2005
- Covington & Burling, 2000-2003
- Law Clerk to the Hon. Richard J. Cardamone, U.S. Court of Appeals, Second Circuit, 1999-2000