Jeff’s practice includes complex litigation at the trial and appellate level, focusing on matters arising from government, regulatory, and criminal and corporate internal investigations.
By Jeffrey M. Hanna, Matthew Orso and Patrick Rowan on Anti-Money Laundering,ComplianceFinancial institutions’ ability to share suspicious activity reports (“SARs”) within the corporate organizational structure serves as an important tool for Bank Secrecy Act compliance and risk avoidance. FinCEN began 2017 by reminding casinos of their ability to share information under this rule. Subject to certain limitations, casinos may share with domestic parents and affiliates suspicious… Continue Reading
By Jeffrey M. Hanna and Patrick Rowan on Anti-Money Laundering,Compliance,Financial Institution RegulationOn the day after his appointment in August 2016, the Associate Director for Enforcement for the Financial Crimes Enforcement Network (FinCEN), Thomas Ott, addressed the National Title 31 Suspicious Activity & Risk Assessment Conference in Las Vegas, Nevada. In his remarks, he (1) covered recent enforcement actions, (2) sought to dispel myths or misconceptions about… Continue Reading
By Patrick Rowan and Jeffrey M. Hanna on Anti-Money LaunderingAttributing observed deficiencies to a lack of a culture of compliance, FinCEN has again targeted a casino for willful violations of the anti-money laundering (“AML”) provisions of the Bank Secrecy Act (“BSA”). This time the casino in FinCEN’s sights is the Sparks Nugget, Inc. d/b/a John Ascuaga’s Nugget (“Sparks Nugget”), located in Sparks, Nevada. In… Continue Reading
By Jeffrey M. Hanna and Jodie Herrmann Lawson on Compliance,Financial Institution RegulationAt the end of February 2016, the Consumer Financial Protection Bureau (CFPB) announced nine priority goals for the next two years. According to its press release, the CFPB set these priorities by balancing the amount of consumer harm observed against the Bureau’s capacity to eliminate or mitigate that harm. The CFPB identified three core tools… Continue Reading
By Jeffrey M. Hanna and Alex J. Brackett on Election and Political LawThe news media has already engaged in rampant speculation regarding the potential candidates from both parties in the 2016 presidential election. Inextricably tied to the talk of political campaigns is the public discussion about campaign finance, particularly with reference to political action committees (PACs). In the wake of the Citizens United decision, the public has… Continue Reading
By Jeffrey M. Hanna on Anti-Bribery and Corruption,ComplianceOch-Ziff Capital Management (Och-Ziff), a publicly traded hedge fund, hasdisclosed that it is the subject of an ongoing investigation by the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC). The inquiry focuses on a “placement fee” Och-Ziff paid in 2007 to a London middleman − Lebanese businessman Mohamad Ali Ajami − to… Continue Reading
By Alex J. Brackett, Jeffrey M. Hanna and Patrick Rowan on Compliance,Financial Institution RegulationOn August 14, 2014, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published revised guidance regarding entities owned by persons whose property and interests in property are blocked pursuant to an Executive Order or regulations administered by OFAC (blocked persons). Fed. Reg. 47726 (August 14, 2014). Under the revised guidance, any entity that… Continue Reading
By Jeffrey M. Hanna on Enforcement and Prosecution Policy and TrendsImagine you are a federal prosecutor and the following fact pattern lands on your desk: a college student has gained unauthorized access to the email account of a candidate for federal office. He changed the email account password and then shared the new password on an Internet message board. Within one day, fearing a possible… Continue Reading
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