Eddie is a member of the firm’s nationally recognized Government Investigations and White Collar Litigation team. His practice includes representing leading financial institutions in government investigations and enforcement actions by various federal agencies. Eddie also focuses on representing corporate and individual clients in connection with internal investigations and grand jury subpoenas.
By Edward M. Nogay, Matthew Orso and Jeffrey M. Hanna on Financial Institution RegulationAt long last, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule establishing a beneficial ownership information reporting requirement for corporations and companies both large and small. In its announcement earlier today, FinCEN explained that the rule will require most companies and corporations registered to do business in the United States to report information about their… Continue Reading
By Edward M. Nogay, Jah Akande, Matthew Orso and Andrew Konia on Financial Institution RegulationOn September 7, 2022, Jimmy Kirby, the Acting Deputy Director of the Financial Crimes Enforcement Network (“FinCEN”), gave remarks during the 2022 Federal Identity Forum & Exposition (“FedID”) on the importance of securing digital identity. In his opening comments, Kirby emphasized digital identity as “fundamental to the effectiveness of every financial institution’s AML/CFT program.”… Continue Reading
By Matthew Orso, Jeffrey M. Hanna and Edward M. Nogay on Anti-Money LaunderingOn January 25, 2022, the Financial Crimes Enforcement Network (“FinCEN”) solicited commentary regarding its proposed rule that would create a time-limited pilot program to expand the ability of financial institutions to share Suspicious Activity Reports (“SARs”) and SAR-related information. (See 31 U.S.C. § 5318(g)(8)). The proposed program would permit a financial institution with a SAR… Continue Reading
By Matthew Orso, Susan C. Rodriguez, Jeffrey M. Hanna and Edward M. Nogay on Anti-Money LaunderingOn September 15, 2020, the Financial Crimes Enforcement Network (“FinCEN”) published a Final Rule bringing banks that lack a federal functional regulator further under its purview. The rule subjects these institutions to minimum standards for anti-money laundering (“AML”) requirements, including a BSA officer, AML policies and procedures, and regular employee training, among other obligations. It… Continue Reading