Subject to Inquiry

Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Jeffrey M. Hanna

Photo of Jeffrey M. Hanna Jeff is co-leader of the firm’s Banking Regulation & Enforcement Practice Group and a senior member of the Government Investigations & White Collar Bank Defense & Counseling and Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) teams. Jeff focuses primarily on the federal Bank Secrecy Act and related state laws and regulations governing financial institutions, including banks, money services businesses (MSBs), and casinos. He regularly represents financial institutions in connection with BSA/AML obligations, including in regulatory and law enforcement investigations, examinations, and day-to-day compliance obligations.

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The Bedeviling Question of Willfulness in the Criminal Context

By Jeffrey M. Hanna on Election and Political Law, Enforcement and Prosecution Policy and Trends, Sanctions, Trade Embargo, and Export Controls
Courts have long struggled with interpreting (and thus instructing a jury on) the statutory element of willfulness. This frequently manifests in the challenge of expressing what level of knowledge the defendant must possess about the law he is accused of violating. Reflective of this challenge, courts have characterized the element of willfulness as “bedeviling,” turning… Continue Reading

Despite Public Perception, Financial Institutions Have Not Received Favored Treatment

By Jeffrey M. Hanna on Anti-Bribery and Corruption, Enforcement and Prosecution Policy and Trends, Securities and Commodities
Following a slew of significant corporate settlements over the last several months — none involving criminal charges being brought against corporations or individuals — federal regulators and law enforcement have heard an increasing outcry over the lack of criminal prosecutions of financial institutions and their executive leadership. Congress, irked by the perceived “Too Big to… Continue Reading

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