Bar Admissions
- New York
- Florida
Court Admissions
- US Supreme Court, 2013
- US District Court, Eastern District of New York, 1975
- US District Court, Southern District of New York, 1975
- US Court of Appeals, Second Circuit, 1975
Clerkships
- Hon. Vincent L. Broderick, US District Court, Southern District of New York
Education
- Fordham University School of Law, JD
- Trinity College, BA
- University of Oxford, Honors Program
Betty Santangelo
Focuses on white-collar criminal defense and securities/bank enforcement.
A former Assistant US Attorney for the Southern District of New York, she concentrates in securities and commodities fraud prosecutions. She represents financial institutions (banks, broker-dealers, mutual funds, FCMs, insurance companies, investment advisers, hedge funds and private equity funds), other corporate entities and individuals in matters brought by the U.S. Attorneys’ offices, by various regulatory agencies, including the SEC, the bank regulatory agencies, the CFTC, FINRA, international regulators and state and local prosecutors.
Betty also has significant experience conducting internal investigations for these entities. In addition, she has served as an independent consultant in SEC enforcement matters examining both the NYSE and a regional broker-dealer.
Before joining Schulte, Betty served as First Vice President and Assistant General Counsel for Merrill Lynch, where she managed the firm's securities and criminal regulatory investigations group and represented the firm and its employees in enforcement proceedings before federal and state regulatory agencies, and in criminal matters before U.S. Attorneys' offices and state prosecutors, as well as in foreign jurisdictions.
She has also served as Division Director of the ABA Litigation Committee and Chair of its Securities Litigation and Broker-Dealer Subcommittees.
She has contributed a chapter on “Representation Prior to Indictment” in the book Defending Federal Criminal Cases: Attacking the Government’s Proof (Law Journal Press, 2009, 2015, 2021), co-authored the “Civil and Criminal Enforcement” chapter of the Insider Trading Law and Compliance Answer Book (Practising Law Institute, 2011–2020) and contributed two chapters in Broker Dealer Regulation (Practising Law Institute, 2009–2010, 2014–2020).
Betty is recognized as a leading lawyer by The Legal 500 US, The Best Lawyers in America, Ethisphere: Attorneys Who Matter, Expert Guide to the World’s Leading White Collar Crime Lawyers, Expert Guide to the World’s Leading Women in Business Law, Who's Who Legal: Business Crime Defence and New York Super Lawyers. She was also presented with the New York Chapter of the National Organization for Women's annual Women of Power and Influence Award.
Nationally recognized for her deep experience in corporate compliance issues, including anti-money laundering, OFAC and FCPA, Betty’s representation of financial institutions in white collar and regulatory matters frequently draws on these areas of experience, including advising financial institutions on their anti-money laundering/OFAC/FCPA procedures. At Merrill Lynch, she was also responsible for oversight of all Bank Secrecy Act reporting and anti-money laundering activities, and the implementation of Merrill Lynch’s anti-money laundering procedures.
Among her many professional activities, she has served as the Securities and Futures Industry’s representative on the Bank Secrecy Act Advisory Group of the U.S. Department of the Treasury. Betty also is a founding member of and has served as counsel to the Securities Industry and Financial Markets Association’s (SIFMA) Anti-Money Laundering and Financial Crimes Committee. In 2014, she was honored by SIFMA for her extraordinary contributions to the committee and recognized for her dedication to improving industry compliance.
In 1998, the Financial Crimes Enforcement Network of the US Treasury Department awarded Betty its Director’s Medal for Exceptional Service. That same year, she represented the U.S. securities industry at the Financial Action Task Force (“FATF”) meeting in Brussels, Belgium. In 2002, she represented SIFMA, the Futures Industry Association and the Investment Company Institute at the FATF meeting in Paris.
Betty is a former adjunct professor at Fordham Law School, where she taught a course on money laundering and founded Fordham Law Women to raise awareness of the issues faced by women in the law school community. In 2019, Fordham Law established the Betty Santangelo Award to recognize alumnae working to advance the careers of women in the legal industry.
She is a much sought-after speaker on corporate compliance, anti-money laundering/OFAC/FCPA, white collar criminal and securities law issues, including at SIFMA, the FIA, ACAMS, the ABA/ABA AML conference and FIBA.
From the Emerald Literati Network, she received an “outstanding paper” award in 2006 for an article she wrote on money laundering enforcement actions and a “highly commended” award in 2011 for an article she wrote on beneficial ownership information and USA PATRIOT Act obligations.
In 2008, she won a Burton Award, which recognizes exceptional legal writing, for an article she wrote on the FCPA. She is a recipient of the YWCA Woman of Achievement award, as well as other awards.
- Involved in numerous representations of large banks and broker-dealers in connection with possible AML/BSA violations before the SEC, FINRA, the bank regulators and FinCEN.
- Conducting internal investigation into possible money laundering and foreign tax fraud by foreign institutional client of U.S. commercial bank.
- Representation of global financial institution in international money laundering investigation.
- Representation of major securities firm in parallel N.Y. District Attorney’s Office, SEC and federal grand jury investigations into possible Martin Act violations, securities fraud, tax evasion and money laundering.
- Independent consultant retained to review the NYSE’s rules, practices and procedures applicable to floor members.
- Representation of foreign banks before OCC in connection with negotiation of settlement agreement and examination by SEC.
- Advise large private equity funds and private investment funds in connection with establishing of AML/sanctions programs.
Books/Treatises
- “Civil and Criminal Enforcement,” Insider Trading Law and Compliance Answer Book (Practising Law Institute), 2011–2020
- Private Equity Funds: Formation and Operation (Practising Law Institute) (contributor)
- Hedge Funds: Formation, Operation and Regulation (ALM Law Journal Press) (contributor)
- “Representation Prior to Indictment,” Defending Federal Criminal Cases: Attacking the Government's Proof (Law Journal Press), 2009, 2015, 2021 (co-author)
- “Anti-Money Laundering Regulations Applicable to Broker-Dealers,” Broker Dealer Regulation (Practising Law Institute), September 2014
- “Anti-Money Laundering,” Practitioner’s Guide for Broker-Dealers (Complinet), Nov. 11, 2010 (co-author)
- “Clearing Broker Liability and Responsibilities,” Broker Dealer Regulation (Practising Law Institute),May 2010 (co-author)
- “Specific Corporate Compliance Challenges by Practice Area: Anti-Money Laundering,” The Corporate Compliance Practice Guide: The Next Generation (Matthew Bender/LexisNexis), 2009 (co-author)
- “Anti-money Laundering Regulation of Broker-Dealers,” Broker Dealer Regulation, Chapter 18, June 2009 (co-author)
- “Mutual Fund Compliance and the Anti-Money Laundering Regulatory Regime, Part I and II,” The Review of Securities & Commodities Regulation, September 2005 and September 2007
- “The Anti-Money Laundering Regime for the Futures Industry,” The Review of Securities & Commodities Regulation, March 2007
- “Suitability in Cyberspace,” Securities & Commodities Regulation, Vol. 34, No. 11, June 13, 2001
- “The Foreign Corrupt Practices Act and Money Laundering,” Conducting Due Diligence (Practising Law Institute), May 1999
- “Money Laundering and Suspicious Activity Reporting,” Securities and Commodities Regulation, Vol. 31, No. 15, Sept. 9, 1998
Articles
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“FinCEN Issues Final Rule Requiring AML Reporting for Real Estate Sector,” Schulte Alert, Nov. 5, 2024
- “The Corporate Transparency Act: Filing Deadline Fast Approaching,” Schulte Alert, Oct. 22, 2024
- “FinCEN Issues Final AML/CFT Program Rule for Certain Investment Advisers,” Schulte Alert, Sept. 30, 2024
- “FinCEN Issues Proposed Rule to Strengthen and Modernize AML/CFT Programs for Financial Institutions,” Schulte Alert, Aug. 16, 2024
- “Sanctions Update: Statutory Amendments and an Interim Final Rule Create Significant Implications for OFAC Sanctions Compliance,” Schulte Alert, June 11, 2024
- “FinCEN Issues Proposed Rule Requiring Customer Identification Programs for Investment Advisers,” Schulte Alert, June 11, 2024
- “FinCEN Issues Proposed Rule to Implement AML Reporting Requirements for Real Estate Sector,” Schulte Alert, May 3, 2024
- “Sanctions Update: OFAC Re-Emphasizes Applicability of Sanctions to Non-US Persons,” Schulte Alert, April 4, 2024
- “FinCEN Once Again Proposes Anti-Money Laundering Program Requirements for Investment Advisers,” Schulte Alert, March 18, 2024
- “Corporate Transparency Act Update: Federal District Court Rules the Act Unconstitutional,” Schulte Alert, March 5, 2024
- “Corporate Transparency Act Update: Beneficial Ownership Reporting Rule Now Effective and FinCEN Is Accepting Reports,” Schulte Alert, Jan. 4, 2024
- “The Corporate Transparency Act: Final Rule on Access to Beneficial Ownership Information,” Schulte Alert, Jan. 2, 2024
- “Anti-Money Laundering Update: Treasury to Re-Propose Long Anticipated AML Program Rules Aimed at Hedge Funds, PE Funds and Certain Investment Advisers,” Schulte Alert, Dec. 22, 2023
- “The Corporate Transparency Act: FinCEN Extends Filing Deadline From 30 to 90 Days For Reporting Companies Created or Registered in 2024,” Schulte Alert, Dec. 1, 2023
- “CFPB Proposes Rule Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications,” Schulte Alert, Nov. 16, 2023
- “California Passes Portions of the Model Money Transmission Modernization Act,” Schulte Alert, Oct. 12, 2023
- “Key Takeaways From Agencies’ Tri-Seal Compliance Note,” Law360, Aug. 25, 2023
- “SEC Exam Staff Issues Alert Highlighting Deficiencies in Broker-Dealers’ AML Programs,” Schulte Alert, Aug. 25, 2023
- “Sanctions Update: OFAC Encourages Voluntary Self-Disclosure for Sanctions Violations,” Schulte Alert, Aug. 2, 2023
- “What To Note In FinCEN, DOJ Action Against Crypto Exchange,” Law360, April 18, 2023
- “Alumnae Founders of Groups for Women and Black Students Speak at Fordham Law Women Symposium,” Fordham Law News, April 4, 2023 (quoted)
- Securities Enforcement Quarterly, Schulte Publication, February 2023
- “FinCEN Issues Proposed Access Rule and Proposed Forms to Further Implement the CTA,” Schulte Alert, Feb. 7, 2023
- “FinCEN Identifies Bitzlato as a 'Primary Money Laundering Concern' in First-Time Use of Section 9714(a) and DOJ Charges Its Founder with Owning an Unlicensed Money Transmitting Business,” Schulte Alert, Feb. 3, 2023
- “NYDFS Releases Guidance for BitLicensees and Limited Purpose Trust Companies on Asset Custody in the Wake of Cryptocurrency Insolvencies,” Schulte Alert, Jan. 31, 2023
- “NYDFS Announces $100 Million Settlement with Coinbase for AntiMoney Laundering Compliance Deficiencies,” Schulte Alert, Jan. 23, 2023
- “AML Recent Developments: What Practitioners Need to Know,” The Review of Securities & Commodities Regulation, Nov. 9, 2022
- “FinCEN Issues Final Rule Requiring Reporting of Beneficial Ownership Information,” Schulte Alert, Oct. 20, 2022
- Securities Enforcement Quarterly, Schulte Publication, August 2022
- “Russian Sanctions Update: OFAC Issues Broad Restrictions on ‘New Investment’ in Russia,” Schulte Alert, June 10, 2022
- Securities Enforcement Quarterly, Schulte Publication, May 2022
- “Russian Sanctions Update: FinCEN and NYDFS Issue Guidance,” Schulte Alert, April 25, 2022
- “Sanctions Update: US Imposes Sweeping Sanctions Against Russia and Belarus,” Schulte Alert, Feb. 28, 2022
- “Sanctions Update: US Begins to Roll Out Sanctions Against Russia,” Schulte Alert, Feb. 23, 2022
- “FinCEN Commences Rulemaking Process to Implement AML Reporting Requirements for Real Estate Sector,” Schulte Alert, Feb. 11, 2022
- Securities Enforcement Quarterly January 2022, Schulte Publication, Jan. 2022
- “FinCEN Issues Notice of Proposed Rulemaking Regarding Beneficial Ownership Information Reporting Requirements Under the Corporate Transparency Act,” Schulte Alert, Jan. 14, 2021
- “US Expands Sanctions Against Belarus, Barring New Sovereign Debt Transactions,” Schulte Alert, Dec. 10, 2021
- Securities Enforcement Quarterly, Schulte Publication, October 2021; republished in the Harvard Law School Forum on Corporate Governance, November 2021
- “FATF Releases Anticipated Guidance for Virtual Assets and Virtual Asset Service Providers, Survey Results on Cross-Border Payments and Proposed Revisions to Beneficial Ownership Standard,” Schulte Alert, Nov. 30, 2021
- “Treasury Issues Reports and Guidance to Assist Industry In Addressing Threats Posed by Certain Virtual Currency Transactions and Ransomware Payments,” Schulte Alert, Oct. 28, 2021
- “FinCEN Issues First National AML/CFT Priorities and Defers Implementation of Priorities and No-Action Letter Process to Future Rulemakings,” Schulte Alert, July 12, 2021
- Securities Enforcement Quarterly, Schulte Publication, July 2021
- “Federal Banking Regulators Update Guidance on Model Risk Management Practices for AML and Sanctions Compliance,” Schulte Alert, June 10, 2021
- “White House Revamps Chinese Securities Trading Ban,” Schulte Alert, June 8, 2021
- Securities Enforcement Quarterly, Schulte Publication, April 2021
- “FinCEN Commences Rulemaking Process for Implementation of Corporate Transparency Act Requiring Disclosure of Beneficial Ownership Information,” Schulte Alert, April 26, 2021; republished in the Harvard Law School Forum on Corporate Governance, May 11, 2021
- “Broker-Dealers and Mutual Funds: Increased Regulatory Focus on Suspicious Activity Monitoring and Reporting Requirements,” Schulte Alert, April 1, 2021
- “US Sanctions on Chinese Company Securities: Further Developments,” Schulte Alert, Jan. 19, 2021
- “Passage of Anti-Money Laundering Act of 2020 Includes Comprehensive BSA/AML Reform Measures,” Schulte Alert, Jan. 7, 2021
- “OFAC Provides Guidance on Trading Ban in Chinese Companies,” Schulte Alert, Dec. 31, 2020
- “FinCEN Releases Notice of Proposed Rulemaking and FAQs Concerning Convertible Virtual Currency and Legal Tender Digital Asset Transactions,” Schulte Alert, Dec. 23, 2020
- “SEC Staff Bulletin Highlights AML Risks Associated with Low-Priced Securities Trading in Omnibus Accounts,” Schulte Alert, Dec. 14, 2020
- “Treasury Issues Advisories Related to Ransomware Attacks,” Schulte Alert, Dec. 1, 2020
- “White House Bans Trading in 31 Chinese Companies,” Schulte Alert, Nov. 13, 2020
- “AML Managers Question FinCEN’s New Effectiveness Test,” FinOps Report, Oct. 7, 2020 (quoted)
- “FinCEN and Banking Agencies Provide Clarification on PEP Screening Best Practices,” Schulte Alert, Oct. 5, 2020
- “AML Update: FinCEN Issues First-Ever Enforcement Guidelines and Federal Banking Agencies Update Enforcement Guidance,” Schulte Alert, Sept. 2, 2020; republished in The Banking Law Journal, February 2021
- “Sanctions Update: OFAC Regulations, Advisories and Enforcement Actions: November 2019 through July 2020,” Schulte Alert, August 7, 2020; republished in The Hedge Fund Journal, September 2020
- “Sanctions Update: US Sanctions Compliance During COVID-19,” Schulte Alert, April 24, 2020
- “US Government Continues to Penalize Unauthorized Disclosures of Suspicious Activity Reports,” Schulte Alert, Feb. 24, 2020
- “Mitigating OFAC Risks in Mergers and Acquisitions,” Schulte Alert, Feb. 3, 2020; republished in Thomson Reuters Westlaw Journal Bankruptcy, March 24, 2020
- “Sanctions Update: DOJ Revises Voluntary Self-Disclosure Policy for Export Control and Sanctions Violations,” Schulte Alert, Jan. 2, 2020
- “OFAC Expands Reporting Obligations and Highlights Importance of Cooperation,” Schulte Alert, Nov. 21, 2019; republished in The Hedge Fund Journal, February 2020
- “Sanctions Update: Iran, Venezuela, Ukraine, Nicaragua and Cuba,” Schulte Alert, Oct. 11, 2019 (co-author)
- “Federal Banking Regulators Issue Joint Statement on BSA/AML Compliance Program Examinations,” Schulte Alert, August 1, 2019 (co-author)
- “OFAC Update: A Framework for Compliance and Recent Settlements,” Schulte Alert, July 12, 2019 (co-author); republished in The Hedge Fund Journal, August 2019
- “FinCEN Assesses Civil Money Penalty Against P2P Currency Exchanger for BSA Violations,” Schulte Alert, April 26, 2019 (co-author)
- “Sanctions Update: Venezuela,” Schulte Alert, April 4, 2019 (co-author)
- “Sanctions Update: OFAC Sanctions Venezuela’s State-Owned Oil Company,” Schulte Alert, Feb. 8, 2019 (co-author)
- “Federal Banking Regulators Issue Joint Statement Encouraging Innovation in BSA/AML Compliance,” Schulte Alert, Dec. 5, 2018 (co-author)
- “Sanctions, Sanctions and More Sanctions!” The Hedge Fund Journal, December 2018 (co-author)
- “Sanctions Update: Iran, Venezuela and Russia,” Schulte Alert, Nov. 13, 2018 (co-author)
- “Arrest of FinCEN Employee for Unlawful Disclosure of SARs and SAR Information,” Schulte Alert, Oct. 19, 2018 (co-author)
- “FinCEN and Federal Banking Agencies Issue Statement on Pooling Resources for BSA Compliance,” Schulte Alert, Oct. 5, 2018 (co-author)
- “Sanctions Update: Iran, Global Magnitsky and Sudan,” Schulte 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,” Schulte Alert, June 4, 2018 (co-author)
- “OFAC Focuses on Oligarchs, Adds Sanctions on Russian Persons and Entities,” Schulte Alert, April 26, 2018 (co-author)
- “NYDFS Issues Guidance to Deter Fraud and Manipulation in Virtual Currency Markets,” Schulte Alert, Feb. 9, 2018 (co-author)
- “Treasury Identifies Russian Political Figures and Oligarchs,” Schulte Alert, Feb. 1, 2018 (co-author)
- “Sanctions and AML Update: North Korea and Venezuela,” Schulte Alert, Sept. 27, 2017 (co-author); republished in The Hedge Fund Journal, October 2017
- “Sanctions Update: U.S. Imposes Immediate Restrictions Relating to Venezuelan Securities,” Schulte Alert, Aug. 28, 2017 (co-author)
- “Sanctions Update: Russia, Iran, North Korea and Venezuela,” Schulte Alert, Aug. 2, 2017 (co-author); republished in The Hedge Fund Journal, August 2017
- “FinCEN Issues Assessment Against Virtual Currency Exchange — the First Enforcement Action Against a Foreign-Located Money Services Business,” Schulte Alert, July 27, 2017 (co-author); republished in PaymentsJournal, Aug. 14, 2017
- “FinCEN Renews GTOs Targeting Real Estate Transactions,” Schulte Alert, March 1, 2017 (co-author)
- “FinCEN Issues Suspicious Activity Report Guidance Concerning Cybersecurity,” Schulte Alert, Nov. 1, 2016 (co-author)
- “DOJ and OFAC Take Enforcement Action Against Canadian Payment Processor,” Schulte 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,” Schulte Alert, July 6, 2016 (co-author); republished in Westlaw Journal — Bank & Lender Liability, Sept. 19, 2016
- “US Eases Sanctions on Burma,” Schulte Alert, May 31, 2016 (co-author)
- “Highlights of FinCEN’s Long-Awaited Customer Due Diligence Final Rule,” Schulte Alert, May 11, 2016 (co-author); republished in The Hedge Fund Journal, June 2016
- “OFAC and BIS Amend Cuba Sanctions Regulations,” Schulte Alert, Feb. 1, 2016 (co-author)
- “New AML Regulatory Initiative Targets Real Estate Industry,” Schulte 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,” Schulte Alert, Jan. 20, 2016 (co-author); republished in Business Crimes Bulletin, June 2016
- “NYDFS Proposes New AML/Sanctions Programs and Annual Certification Requirements for Banks, Money Transmitters and Check Cashers,” Schulte Alert, Dec. 4, 2015 (co-author)
- “The New AML Rules: Implications for Private Fund Managers,” Schulte 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)
- “BHP Billiton Settles with SEC for $25 Million for Providing Foreign Officials with Luxury Travel to Olympics,” Schulte Alert, May 21, 2015 (co-author)
- “PayPal Settlement Highlights OFAC Risks for Money Services Businesses,” Schulte Alert, March 27, 2015 (co-author)
- “Federal and State Regulators Target Compliance Officers,” Schulte Alert, Feb. 20, 2015 (co-author)
- “Sanctions Update: Crimea,” Schulte Alert, Feb. 5, 2015 (co-author); republished in Westlaw Journal – Securities Litigation & Regulation, March 5, 2015
- “FinCEN’s Much Anticipated Proposed Rule on Customer Due Diligence Is Finally Here,” Financial Fraud Law Report, November/December 2014 (co-author)
- “Sanctions Update: Sectoral Sanctions Against Russia Escalate,” Schulte Alert, Sept. 18, 2014 (co-author); republished in Westlaw Journal – Securities Litigation & Regulation, Oct. 16, 2014
- “FinCEN’s Much-Anticipated Proposed Rule on Customer Due Diligence Is Finally Here,” Schulte Alert, Aug. 8, 2014 (co-author)
- Schulte Insider Trading Developments Newsletter, Summer 2014 (contributor)
- “Threatened Sectoral Sanctions Against Russia Become Reality,” Schulte Alert, July 30, 2014 (co-author)
- “Escalating U.S.–Russia Tensions Lead to New Sanctions, Heightened AML Risks,” Schulte Alert, April 4, 2014 (co-author)
- “Funds Face New Sanctions, AML Risks in Wake of Escalating U.S.–Russia Tensions,” Schulte Alert, April 4, 2014 (co-author)
- “FinCEN Issues Final Rules Relating to Money Services Business (MSB) Definitions,” Journal of Investment Compliance, April 2012 (co-author)
- “Recent FCPA Developments Highlight Risk of Individual Liability,” Financial Fraud Law Report, March 2012 (co-author)
- “The FCPA and AML Statutes: Prosecutors Increasingly Combining Charges, to Great Effect,” Business Crimes Bulletin, January 2012 (co-author)
- “The FCPA and AML Statutes: The Prosecutor’s Combined Weapon of Choice,” Business Crimes Bulletin, December 2011 (co-author)
- “Government Launches FCPA Inquiry into Investments by Sovereign Wealth Funds in U.S. Banks and Private Equity Firms,” Financial Fraud Law Report, July/August 2011 (co-author)
- “SEC Extends and Modifies Its No-Action Relief for BDs to Rely on RIAs for Performance of CIP” (Complinet), March 8, 2011 (co-author)
- “FinCEN and Regulators Issue Joint Guidance on Obtaining Beneficial Ownership Information, Potentially Expanding Certain Financial Institutions’ USA PATRIOT Act Obligations,” Journal of Investment Compliance, Nov. 22, 2010
- “FinCEN and SEC Sanction Broker-Dealer and Chief Compliance Officer for AML Deficiencies Relating to Foreign Sub-Accounts” (Complinet), Oct. 6, 2010
- “Bribery Act 2010,” The Hedge Fund Journal, September 2010 (co-author)
- “Practice Note: Developing an Effective AML Compliance Program for Hedge Funds” (Complinet), Feb. 12, 2008
- “The Foreign Corrupt Practices Act: Recent Cases and Enforcement Trends,” Journal of Investment Compliance, Vol. 8, No. 3, 2007 (co-author)
- “Ask Not For Whom the Bell Tolls, It May Toll For You Next: Intensified Anti-Money Laundering Enforcement Transforms the Regulatory Landscape,” Journal of Investment Compliance, Vol. 6, No.1, Fall 2005
- “AML Programs for Financial Institutions Under Section 352 of the USA Patriot Act,” Banking & Financial Services Policy Report, Vol. 21, No. 7, July 2002
- “Anti-Money Laundering Provisions of the USA PATRIOT Act of 2001,” CCH, April 2002
- “Are Self Regulatory Organizations State Actors? Two Recent Cases Take Contrasting Perspectives,” The Journal of Investment Compliance, Vol. 2, No. 1, Summer 2001
- “2001: A Money Laundering Space Odyssey,” Securities Industry Association Compliance and Legal Seminar on SIA Website, March 2001
- “Did Bankers Trust Alter The Rules?,” New York Law Journal, Corporate Counsel, at S4, Nov. 20, 2000
- “How Safe Is The Bank Secrecy Act Safe Harbor?,” Journal of Investment Compliance, Vol. 1, No. 2, Fall 2000
- “International Ramifications of U.S. Anti-Money Laundering Policy: Whose Law is the United States Enforcing?,” Journal of International Banking Law, Vol. 15, Issue 4/5, April/May 2000
- “Back to the Future: How Recent Events Have Revived the Call for More Stringent Anti-Money Laundering Regulation,” Banking Policy Report, Vol. 19, No. 6, March 20, 2000
- “Money Laundering In The Millennium: A Broker-Dealer’s Guide To KYC, SAR & OFAC,” Securities Industry Association Compliance and Legal Division Annual Seminar on SIA Website, March 2000
- “Money Laundering and Suspicious Activity Reporting: Now What’s a Broker-Dealer To Do?,” Money Laundering Alert, April-July 1999 (published in four parts)
- “Never a Dull Moment: Hot Topics in AML and Financial Crimes,” SIFMA Anti-Money Laundering & Financial Crimes Conference, May 2023
- Fordham Law Women's Fifth Annual Symposium, March 2023
- “Industry Hot Topics,” SIFMA Anti-Money Laundering & Financial Crimes Conference, May 2022
- FIA Law & Compliance Division Conference, April 2021
- “Financial Crimes Case Studies: You Make the Call!,”SIFMA Anti-Money Laundering & Financial Crimes Conference, Feb. 2021
- “Confusion Worse Confounded: AML in the Capital Markets,” SIFMA Anti-Money Laundering & Financial Crimes Conference, New York, February 2019
- “Hot Topics: AML, Cybersecurity, Privacy, GDPR,” FIA Law & Compliance Division 40th Annual Law & Compliance Division Conference, Washington DC, May 2018
- “Shells and Pillars: Are You Ready?,” SIFMA Anti-Money Laundering & Financial Crimes Conference, New York, February 2018
- “DFS, State, and OFAC Officials Weigh-In on Regulatory Hot Buttons Governing the Insurance and Reinsurance Industries,” 8th Annual Forum on AML & OFAC Compliance for the Insurance Industry, January 2018
- “Developments in AML – What’s New?,” FIA Law & Compliance Division 39th Annual Law & Compliance Conference on the Regulation of Futures, Derivatives and OTC Products, May 2017
- “Crisis Management and Reactions to Breaking Events,” SIFMA 17th Annual Anti-Money Laundering & Financial Crimes Conference, February 2017
- “Regulatory and Enforcement Roundtable: Perspectives from Federal and State Agencies that Govern the Insurance and Reinsurance Industries,” ACI 7th Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2017
- “What to Do When You Suspect a Violation? Tips for Internal Investigations and Determining the Value of a Voluntary Self-Disclosure,” ACI 7th Annual New York Forum on Economic Sanctions, December 2016
- “A Financial Institution Under Criminal Investigation – Strategic Issues,” Deloitte Tenth Annual AML Conference, October 2016
- “Sanctioning Compliance Officers: External and Internal Sanctions on Compliance Officers,” NYU Law Compliance: New Risks, Challenges, and Approaches Conference, October 2016
- “Customer Due Diligence in a Global AML Environment,” SIFMA 16th Annual Anti-Money Laundering & Financial Crimes Conference, April 2016
- Co-Moderator, “Regulatory and Enforcement Roundtable: Perspectives from OFAC, the Department of State, the DOJ, and Other Federal and State Agencies That Govern the Insurance and Reinsurance Industries,” ACI 6th Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2016
- “Meeting Government’s Expectations: How Much Is Enough Due Diligence to Protect Your Organization?,” ACI 6th Annual Economic Sanctions Bootcamp, December 2015
- “AML Compliance: Hot Topics,” SIFMA Compliance & Legal Society Annual Seminar, March 2015
- “Compliance Officers and Personal Liability: Are You At Risk?,” ACAMS Webinar, March 2015
- “Lessons Learned from Enforcement,” SIFMA 15th Annual Anti-Money Laundering & Financial Crimes Conference, February 2015
- Co-Moderator, “Regulatory and Enforcement Roundtable: Perspectives from the Department of State, the Office of the New York State Attorney General, the Secret Service, and Other Federal and State Agencies That Govern the Insurance and Reinsurance Industries,” ACI 5th Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2015
- “Know Your Product: Money Laundering Risks in New and Complex Products,” ABA Money Laundering Enforcement Conference, November 2014
- “Current Regulatory and International Issues,” FIA Law & Compliance Regulatory Roundup: A Mid-Year Review for Chicago Members, September 2014
- “AML Compliance: Hot Topics,” SIFMA Compliance and Legal Society Annual Seminar, April 2014
- Moderator, “AML and Beyond: The Intersection of AML, Anti-Corruption and Sanctions,” SIFMA 14th Annual Anti-Money Laundering and Financial Crimes Conference, January 2014
- Co-Moderator, “Regulatory and Enforcement Roundtable: Perspectives from the Department of State, the DOJ, the U.S. Attorney’s Office, the Office of the New York State Attorney General, and Other Federal and State Agencies That Govern the Insurance Industry,” ACI 4th Annual Forum on AML & OFAC Compliance for the Insurance Industry, January 2014
- Co-Chair, ACI 4th Economic Sanctions Boot Camp, December 2013
- “AML Compliance — Hot Topics,” SIFMA Compliance and Legal Society Annual Seminar, March 2013
- Moderator, “Significant Sanctions Enforcement Actions and Other Financial Crime Developments,” SIFMA 13th Annual Anti-Money Laundering & Financial Crimes Conference, February 2013
- “Beneficial Ownership: Will A Risk-Based Approach Survive?” and “Broker Dealer & Wealth Management,” FIBA 13th Annual Anti-Money Laundering Compliance Conference, February 2013
- Moderator, “Conducting Effective Internal Investigations into Potential Money Laundering, Fraud, Sanctions Violations, or FCPA Violations,” ACI 3rd Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2013
- “The Aftermath of the $619 Million ING Case, and What It Says About Sanctions Penalty Calculations: Mitigating and Aggravating Factors for Financial Institutions, Non-Regulated Entities and Individuals,” ACI OFAC Boot Camp, December 2012
- “Regulatory Investigations,” PLI Bet the Company Litigation, September 2012
- “Enforcement Against Regulated Financial Institutions,” ACI 5th Advanced Forum on OFAC Enforcement and Compliance, April 2012
- “Securities Focus: Reverse Mergers, Penny Stock and Micro-Cap Securities Fraud — What are the AML Risks and Regulatory Expectations?,” ACAMS 17th Annual International Anti-Money Laundering Conference, March 2012
- “AML Compliance — Hot Topics,” SIFMA 2012 Compliance and Legal Society Annual Seminar, March 2012
- “Ten Years After 9/11: A Retrospective On How We Got Here” and “‘Who's On First?’ – Managing the Allocation of AML Responsibilities in a New Regulatory Environment,” SIFMA 12th Annual Anti-Money Laundering and Financial Crimes Conference, February 2012
- “Conducting Internal Investigations into Potential Money Laundering, Sanctions Violations, or FCPA Violations,” ACI 2nd Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2012
- “Assessing the Price of Sanctions Violations by U.S. and Non-U.S. Entities, and Individuals: The Agencies’ Approach to Global Investigations, Enforcement and Penalty Calculations,” ACI OFAC Boot Camp, December 2011
- “Gifts, Entertainment & Hospitality in High Risk Markets — A Practical Guide on What You Can and Can’t Do,” ACI 26th National Conference on the Foreign Corrupt Practices Act, November 2011
- “AML Monitoring,” SEC Roundtable on Microcap Securities, October 2011
- “Focus on Securities: Creating Optimal Customer Surveillance Programs” and “Combating Consistent Anti-Money Laundering Challenges: Topical Discussions With Subject Matter Experts,” ACAMS 10th Annual International Anti-Money Laundering Conference, September 2011
- “AML Compliance: Hot Topics,” SIFMA Compliance & Legal Society Annual Seminar, March 2011
- “Regulatory and Enforcement Roundtable,” ACI AML and OFAC, January 2011
- “AML, FCPA and OFAC: The Intersection of Three Key Risk Areas,” Schulte 20th Annual Private Investment Funds Seminar, January 2011
- “Fundamentals of FCPA Compliance: The Foreign Corrupt Practices Act Demystified,” ACI 24th Global Conference on the Foreign Corrupt Practices Act, November 2010
- “Practical Approach to Combating Consistent Anti-Money Laundering Challenges,” ACAMS 9th Annual International Anti-Money Laundering Conference, September 2010
- “AML Compliance — Current Issues,” SIFMA CL 2010 Annual Seminar, May 2010
- Moderator, “Regulator Panel — Keeping Current With Regulatory Developments to Ensure Your Institution Remains Compliant,” SIFMA 10th Annual Anti-Money Laundering Conference, March 2010
- “FCPA,” Deloitte Third Annual AML Compliance Conference, November 2009
- “Enforcement Actions — Monitoring,” ACAMS/Morgan Stanley, October 2009
- Moderator, “Regulators Insights: Avoid Penalties and Optimize Your Firm's Defense by Complying With the Latest AML and Fraud Regulations” and “Managing Compliance Requirements for Clearing and Introducing Firms in an Era of Increased Scrutiny and Reduced Resources,” 19th Annual AMLAC & Fraud Forum, October 2009
- “Money Laundering and Asset Forfeiture,” ABA’s 23rd Annual National Institute on White Collar Crime, March 2009
- SIFMA Annual Anti-Money Laundering Conference, 2001–10
- “Q&A Session: ‘Ask the Regulators’,” 2nd Annual Anti-Money Laundering & Counter-Terrorist Financing Forum, November 2007
- SIFMA Law & Compliance Division Annual Seminar, 1987–2010
- SIFMA Compliance & Legal Division Mid-Year Compliance Conference, 2004–06
- Co-chair, Institutional Investor’s Anti-Money Laundering and Counter-Terrorist Financing Forum, 2005-06
- “AML Guidance for Investment Advisors,” Investment Management Compliance Summit, September 2006
- FIA Law and Compliance Seminar, 2002–06
- Institute for International Research on Bank Secrecy Act and Anti-Money Laundering, 1996-2005 (Co-chair of program 1999–05)
- Co-chair, ICM Conference on Money Laundering, 1999–2002
- Member, Board of Directors of National Organization of Italian American Women, 2009–Present;
- Chair, 2012–2014
- Chair Elect, 2012
- Vice Chair, 2009–2011
- Former Member, Editorial Board of Complinet
- Member, Board of Trustees of Federal Bar Council Foundation, 1997–2003; 2005–2008; 2012–2019
- Member, Fordham Law Alumni Association, Board of Directors, 1997–Present
- Member, New York City Bar Association, Federal Courts Committee, 1993–1994
- Division Co-director, ABA Litigation Committee, 1991–1992
- Chair/Co-chair, ABA Securities Litigation Committee, 1989–1991
- Chair, Broker/Dealer Sub-Committee of Litigation Committee, 1987–1989
- Member, ABA White Collar Crime Committee, 1993–Present
- Secretary, New York Women's Bar Association, 1976–1977
- Founder, Fordham Law Women, 1972
- Professional Activities
- Securities Industry and Futures Industry Representative, U.S. Treasury Department Bank Secrecy Act Advisory Group, 1995–2008
- Member, SIFMA Anti-Money Laundering and Financial Crimes Committee, 2014–Present; Counsel, 2000–2014
- Member of U.S. Delegation to FATF, October 2002
- Chair, Ad Hoc Securities Industry Group on Bank Secrecy Act and Anti-Money Laundering, 1995–2000
- U.S. Securities Industry Representative, Financial Action Task Force, 1998
- The Best Lawyers in America
- Ethisphere: Attorneys Who Matter
- Expert Guide to the World’s Leading White Collar Crime Lawyers
- Expert Guide to the World’s Leading Women in Business Law (White Collar Crime)
- Who's Who Legal: Business Crime Defence
- The Legal 500 US
- New York Super Lawyers
- Top Women Attorneys in the New York Metro Area
- 2014 Recipient, SIFMA Award in recognition of extraordinary contributions to the Anti-Money Laundering and Financial Crimes Committee
- 2011 Recipient, Highly Commended Award, Emerald Literati Network
- 2009 Recipient, NOW-NYC Women of Power & Influence Award
- 2008 Recipient, Burton Award for Distinguished Legal Writing for article titled "The Foreign Corrupt Practices Act: Recent Cases and Enforcement Trends"
- 2006 Recipient, Outstanding Paper Award, Emerald Literati Network
- 1998 Recipient, Director's Medal for Exceptional Service, Financial Crimes Enforcement network of the United States Treasury Department
- 1988 Recipient, YWCA Women of Achievement Award
- Merrill Lynch Pierce Fenner and Smith Inc., 1983-1997
- First Vice President and Assistant General Counsel
- U.S. Attorney’s Office, Southern District of New York, 1977-1983
- Assistant U.S. Attorney
- Fordham University School of Law, 1982-1984, 2003
- Adjunct Professor of Law
- Martin, Obermaier & Morvillo, 1974–1976
- Associate
- Involved in numerous representations of large banks and broker-dealers in connection with possible AML/BSA violations before the SEC, FINRA, the bank regulators and FinCEN.
- Conducting internal investigation into possible money laundering and foreign tax fraud by foreign institutional client of U.S. commercial bank.
- Representation of global financial institution in international money laundering investigation.
- Representation of major securities firm in parallel N.Y. District Attorney’s Office, SEC and federal grand jury investigations into possible Martin Act violations, securities fraud, tax evasion and money laundering.
- Independent consultant retained to review the NYSE’s rules, practices and procedures applicable to floor members.
- Representation of foreign banks before OCC in connection with negotiation of settlement agreement and examination by SEC.
- Advise large private equity funds and private investment funds in connection with establishing of AML/sanctions programs.
Books/Treatises
- “Civil and Criminal Enforcement,” Insider Trading Law and Compliance Answer Book (Practising Law Institute), 2011–2020
- Private Equity Funds: Formation and Operation (Practising Law Institute) (contributor)
- Hedge Funds: Formation, Operation and Regulation (ALM Law Journal Press) (contributor)
- “Representation Prior to Indictment,” Defending Federal Criminal Cases: Attacking the Government's Proof (Law Journal Press), 2009, 2015, 2021 (co-author)
- “Anti-Money Laundering Regulations Applicable to Broker-Dealers,” Broker Dealer Regulation (Practising Law Institute), September 2014
- “Anti-Money Laundering,” Practitioner’s Guide for Broker-Dealers (Complinet), Nov. 11, 2010 (co-author)
- “Clearing Broker Liability and Responsibilities,” Broker Dealer Regulation (Practising Law Institute),May 2010 (co-author)
- “Specific Corporate Compliance Challenges by Practice Area: Anti-Money Laundering,” The Corporate Compliance Practice Guide: The Next Generation (Matthew Bender/LexisNexis), 2009 (co-author)
- “Anti-money Laundering Regulation of Broker-Dealers,” Broker Dealer Regulation, Chapter 18, June 2009 (co-author)
- “Mutual Fund Compliance and the Anti-Money Laundering Regulatory Regime, Part I and II,” The Review of Securities & Commodities Regulation, September 2005 and September 2007
- “The Anti-Money Laundering Regime for the Futures Industry,” The Review of Securities & Commodities Regulation, March 2007
- “Suitability in Cyberspace,” Securities & Commodities Regulation, Vol. 34, No. 11, June 13, 2001
- “The Foreign Corrupt Practices Act and Money Laundering,” Conducting Due Diligence (Practising Law Institute), May 1999
- “Money Laundering and Suspicious Activity Reporting,” Securities and Commodities Regulation, Vol. 31, No. 15, Sept. 9, 1998
Articles
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“FinCEN Issues Final Rule Requiring AML Reporting for Real Estate Sector,” Schulte Alert, Nov. 5, 2024
- “The Corporate Transparency Act: Filing Deadline Fast Approaching,” Schulte Alert, Oct. 22, 2024
- “FinCEN Issues Final AML/CFT Program Rule for Certain Investment Advisers,” Schulte Alert, Sept. 30, 2024
- “FinCEN Issues Proposed Rule to Strengthen and Modernize AML/CFT Programs for Financial Institutions,” Schulte Alert, Aug. 16, 2024
- “Sanctions Update: Statutory Amendments and an Interim Final Rule Create Significant Implications for OFAC Sanctions Compliance,” Schulte Alert, June 11, 2024
- “FinCEN Issues Proposed Rule Requiring Customer Identification Programs for Investment Advisers,” Schulte Alert, June 11, 2024
- “FinCEN Issues Proposed Rule to Implement AML Reporting Requirements for Real Estate Sector,” Schulte Alert, May 3, 2024
- “Sanctions Update: OFAC Re-Emphasizes Applicability of Sanctions to Non-US Persons,” Schulte Alert, April 4, 2024
- “FinCEN Once Again Proposes Anti-Money Laundering Program Requirements for Investment Advisers,” Schulte Alert, March 18, 2024
- “Corporate Transparency Act Update: Federal District Court Rules the Act Unconstitutional,” Schulte Alert, March 5, 2024
- “Corporate Transparency Act Update: Beneficial Ownership Reporting Rule Now Effective and FinCEN Is Accepting Reports,” Schulte Alert, Jan. 4, 2024
- “The Corporate Transparency Act: Final Rule on Access to Beneficial Ownership Information,” Schulte Alert, Jan. 2, 2024
- “Anti-Money Laundering Update: Treasury to Re-Propose Long Anticipated AML Program Rules Aimed at Hedge Funds, PE Funds and Certain Investment Advisers,” Schulte Alert, Dec. 22, 2023
- “The Corporate Transparency Act: FinCEN Extends Filing Deadline From 30 to 90 Days For Reporting Companies Created or Registered in 2024,” Schulte Alert, Dec. 1, 2023
- “CFPB Proposes Rule Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications,” Schulte Alert, Nov. 16, 2023
- “California Passes Portions of the Model Money Transmission Modernization Act,” Schulte Alert, Oct. 12, 2023
- “Key Takeaways From Agencies’ Tri-Seal Compliance Note,” Law360, Aug. 25, 2023
- “SEC Exam Staff Issues Alert Highlighting Deficiencies in Broker-Dealers’ AML Programs,” Schulte Alert, Aug. 25, 2023
- “Sanctions Update: OFAC Encourages Voluntary Self-Disclosure for Sanctions Violations,” Schulte Alert, Aug. 2, 2023
- “What To Note In FinCEN, DOJ Action Against Crypto Exchange,” Law360, April 18, 2023
- “Alumnae Founders of Groups for Women and Black Students Speak at Fordham Law Women Symposium,” Fordham Law News, April 4, 2023 (quoted)
- Securities Enforcement Quarterly, Schulte Publication, February 2023
- “FinCEN Issues Proposed Access Rule and Proposed Forms to Further Implement the CTA,” Schulte Alert, Feb. 7, 2023
- “FinCEN Identifies Bitzlato as a 'Primary Money Laundering Concern' in First-Time Use of Section 9714(a) and DOJ Charges Its Founder with Owning an Unlicensed Money Transmitting Business,” Schulte Alert, Feb. 3, 2023
- “NYDFS Releases Guidance for BitLicensees and Limited Purpose Trust Companies on Asset Custody in the Wake of Cryptocurrency Insolvencies,” Schulte Alert, Jan. 31, 2023
- “NYDFS Announces $100 Million Settlement with Coinbase for AntiMoney Laundering Compliance Deficiencies,” Schulte Alert, Jan. 23, 2023
- “AML Recent Developments: What Practitioners Need to Know,” The Review of Securities & Commodities Regulation, Nov. 9, 2022
- “FinCEN Issues Final Rule Requiring Reporting of Beneficial Ownership Information,” Schulte Alert, Oct. 20, 2022
- Securities Enforcement Quarterly, Schulte Publication, August 2022
- “Russian Sanctions Update: OFAC Issues Broad Restrictions on ‘New Investment’ in Russia,” Schulte Alert, June 10, 2022
- Securities Enforcement Quarterly, Schulte Publication, May 2022
- “Russian Sanctions Update: FinCEN and NYDFS Issue Guidance,” Schulte Alert, April 25, 2022
- “Sanctions Update: US Imposes Sweeping Sanctions Against Russia and Belarus,” Schulte Alert, Feb. 28, 2022
- “Sanctions Update: US Begins to Roll Out Sanctions Against Russia,” Schulte Alert, Feb. 23, 2022
- “FinCEN Commences Rulemaking Process to Implement AML Reporting Requirements for Real Estate Sector,” Schulte Alert, Feb. 11, 2022
- Securities Enforcement Quarterly January 2022, Schulte Publication, Jan. 2022
- “FinCEN Issues Notice of Proposed Rulemaking Regarding Beneficial Ownership Information Reporting Requirements Under the Corporate Transparency Act,” Schulte Alert, Jan. 14, 2021
- “US Expands Sanctions Against Belarus, Barring New Sovereign Debt Transactions,” Schulte Alert, Dec. 10, 2021
- Securities Enforcement Quarterly, Schulte Publication, October 2021; republished in the Harvard Law School Forum on Corporate Governance, November 2021
- “FATF Releases Anticipated Guidance for Virtual Assets and Virtual Asset Service Providers, Survey Results on Cross-Border Payments and Proposed Revisions to Beneficial Ownership Standard,” Schulte Alert, Nov. 30, 2021
- “Treasury Issues Reports and Guidance to Assist Industry In Addressing Threats Posed by Certain Virtual Currency Transactions and Ransomware Payments,” Schulte Alert, Oct. 28, 2021
- “FinCEN Issues First National AML/CFT Priorities and Defers Implementation of Priorities and No-Action Letter Process to Future Rulemakings,” Schulte Alert, July 12, 2021
- Securities Enforcement Quarterly, Schulte Publication, July 2021
- “Federal Banking Regulators Update Guidance on Model Risk Management Practices for AML and Sanctions Compliance,” Schulte Alert, June 10, 2021
- “White House Revamps Chinese Securities Trading Ban,” Schulte Alert, June 8, 2021
- Securities Enforcement Quarterly, Schulte Publication, April 2021
- “FinCEN Commences Rulemaking Process for Implementation of Corporate Transparency Act Requiring Disclosure of Beneficial Ownership Information,” Schulte Alert, April 26, 2021; republished in the Harvard Law School Forum on Corporate Governance, May 11, 2021
- “Broker-Dealers and Mutual Funds: Increased Regulatory Focus on Suspicious Activity Monitoring and Reporting Requirements,” Schulte Alert, April 1, 2021
- “US Sanctions on Chinese Company Securities: Further Developments,” Schulte Alert, Jan. 19, 2021
- “Passage of Anti-Money Laundering Act of 2020 Includes Comprehensive BSA/AML Reform Measures,” Schulte Alert, Jan. 7, 2021
- “OFAC Provides Guidance on Trading Ban in Chinese Companies,” Schulte Alert, Dec. 31, 2020
- “FinCEN Releases Notice of Proposed Rulemaking and FAQs Concerning Convertible Virtual Currency and Legal Tender Digital Asset Transactions,” Schulte Alert, Dec. 23, 2020
- “SEC Staff Bulletin Highlights AML Risks Associated with Low-Priced Securities Trading in Omnibus Accounts,” Schulte Alert, Dec. 14, 2020
- “Treasury Issues Advisories Related to Ransomware Attacks,” Schulte Alert, Dec. 1, 2020
- “White House Bans Trading in 31 Chinese Companies,” Schulte Alert, Nov. 13, 2020
- “AML Managers Question FinCEN’s New Effectiveness Test,” FinOps Report, Oct. 7, 2020 (quoted)
- “FinCEN and Banking Agencies Provide Clarification on PEP Screening Best Practices,” Schulte Alert, Oct. 5, 2020
- “AML Update: FinCEN Issues First-Ever Enforcement Guidelines and Federal Banking Agencies Update Enforcement Guidance,” Schulte Alert, Sept. 2, 2020; republished in The Banking Law Journal, February 2021
- “Sanctions Update: OFAC Regulations, Advisories and Enforcement Actions: November 2019 through July 2020,” Schulte Alert, August 7, 2020; republished in The Hedge Fund Journal, September 2020
- “Sanctions Update: US Sanctions Compliance During COVID-19,” Schulte Alert, April 24, 2020
- “US Government Continues to Penalize Unauthorized Disclosures of Suspicious Activity Reports,” Schulte Alert, Feb. 24, 2020
- “Mitigating OFAC Risks in Mergers and Acquisitions,” Schulte Alert, Feb. 3, 2020; republished in Thomson Reuters Westlaw Journal Bankruptcy, March 24, 2020
- “Sanctions Update: DOJ Revises Voluntary Self-Disclosure Policy for Export Control and Sanctions Violations,” Schulte Alert, Jan. 2, 2020
- “OFAC Expands Reporting Obligations and Highlights Importance of Cooperation,” Schulte Alert, Nov. 21, 2019; republished in The Hedge Fund Journal, February 2020
- “Sanctions Update: Iran, Venezuela, Ukraine, Nicaragua and Cuba,” Schulte Alert, Oct. 11, 2019 (co-author)
- “Federal Banking Regulators Issue Joint Statement on BSA/AML Compliance Program Examinations,” Schulte Alert, August 1, 2019 (co-author)
- “OFAC Update: A Framework for Compliance and Recent Settlements,” Schulte Alert, July 12, 2019 (co-author); republished in The Hedge Fund Journal, August 2019
- “FinCEN Assesses Civil Money Penalty Against P2P Currency Exchanger for BSA Violations,” Schulte Alert, April 26, 2019 (co-author)
- “Sanctions Update: Venezuela,” Schulte Alert, April 4, 2019 (co-author)
- “Sanctions Update: OFAC Sanctions Venezuela’s State-Owned Oil Company,” Schulte Alert, Feb. 8, 2019 (co-author)
- “Federal Banking Regulators Issue Joint Statement Encouraging Innovation in BSA/AML Compliance,” Schulte Alert, Dec. 5, 2018 (co-author)
- “Sanctions, Sanctions and More Sanctions!” The Hedge Fund Journal, December 2018 (co-author)
- “Sanctions Update: Iran, Venezuela and Russia,” Schulte Alert, Nov. 13, 2018 (co-author)
- “Arrest of FinCEN Employee for Unlawful Disclosure of SARs and SAR Information,” Schulte Alert, Oct. 19, 2018 (co-author)
- “FinCEN and Federal Banking Agencies Issue Statement on Pooling Resources for BSA Compliance,” Schulte Alert, Oct. 5, 2018 (co-author)
- “Sanctions Update: Iran, Global Magnitsky and Sudan,” Schulte 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,” Schulte Alert, June 4, 2018 (co-author)
- “OFAC Focuses on Oligarchs, Adds Sanctions on Russian Persons and Entities,” Schulte Alert, April 26, 2018 (co-author)
- “NYDFS Issues Guidance to Deter Fraud and Manipulation in Virtual Currency Markets,” Schulte Alert, Feb. 9, 2018 (co-author)
- “Treasury Identifies Russian Political Figures and Oligarchs,” Schulte Alert, Feb. 1, 2018 (co-author)
- “Sanctions and AML Update: North Korea and Venezuela,” Schulte Alert, Sept. 27, 2017 (co-author); republished in The Hedge Fund Journal, October 2017
- “Sanctions Update: U.S. Imposes Immediate Restrictions Relating to Venezuelan Securities,” Schulte Alert, Aug. 28, 2017 (co-author)
- “Sanctions Update: Russia, Iran, North Korea and Venezuela,” Schulte Alert, Aug. 2, 2017 (co-author); republished in The Hedge Fund Journal, August 2017
- “FinCEN Issues Assessment Against Virtual Currency Exchange — the First Enforcement Action Against a Foreign-Located Money Services Business,” Schulte Alert, July 27, 2017 (co-author); republished in PaymentsJournal, Aug. 14, 2017
- “FinCEN Renews GTOs Targeting Real Estate Transactions,” Schulte Alert, March 1, 2017 (co-author)
- “FinCEN Issues Suspicious Activity Report Guidance Concerning Cybersecurity,” Schulte Alert, Nov. 1, 2016 (co-author)
- “DOJ and OFAC Take Enforcement Action Against Canadian Payment Processor,” Schulte 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,” Schulte Alert, July 6, 2016 (co-author); republished in Westlaw Journal — Bank & Lender Liability, Sept. 19, 2016
- “US Eases Sanctions on Burma,” Schulte Alert, May 31, 2016 (co-author)
- “Highlights of FinCEN’s Long-Awaited Customer Due Diligence Final Rule,” Schulte Alert, May 11, 2016 (co-author); republished in The Hedge Fund Journal, June 2016
- “OFAC and BIS Amend Cuba Sanctions Regulations,” Schulte Alert, Feb. 1, 2016 (co-author)
- “New AML Regulatory Initiative Targets Real Estate Industry,” Schulte 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,” Schulte Alert, Jan. 20, 2016 (co-author); republished in Business Crimes Bulletin, June 2016
- “NYDFS Proposes New AML/Sanctions Programs and Annual Certification Requirements for Banks, Money Transmitters and Check Cashers,” Schulte Alert, Dec. 4, 2015 (co-author)
- “The New AML Rules: Implications for Private Fund Managers,” Schulte 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)
- “BHP Billiton Settles with SEC for $25 Million for Providing Foreign Officials with Luxury Travel to Olympics,” Schulte Alert, May 21, 2015 (co-author)
- “PayPal Settlement Highlights OFAC Risks for Money Services Businesses,” Schulte Alert, March 27, 2015 (co-author)
- “Federal and State Regulators Target Compliance Officers,” Schulte Alert, Feb. 20, 2015 (co-author)
- “Sanctions Update: Crimea,” Schulte Alert, Feb. 5, 2015 (co-author); republished in Westlaw Journal – Securities Litigation & Regulation, March 5, 2015
- “FinCEN’s Much Anticipated Proposed Rule on Customer Due Diligence Is Finally Here,” Financial Fraud Law Report, November/December 2014 (co-author)
- “Sanctions Update: Sectoral Sanctions Against Russia Escalate,” Schulte Alert, Sept. 18, 2014 (co-author); republished in Westlaw Journal – Securities Litigation & Regulation, Oct. 16, 2014
- “FinCEN’s Much-Anticipated Proposed Rule on Customer Due Diligence Is Finally Here,” Schulte Alert, Aug. 8, 2014 (co-author)
- Schulte Insider Trading Developments Newsletter, Summer 2014 (contributor)
- “Threatened Sectoral Sanctions Against Russia Become Reality,” Schulte Alert, July 30, 2014 (co-author)
- “Escalating U.S.–Russia Tensions Lead to New Sanctions, Heightened AML Risks,” Schulte Alert, April 4, 2014 (co-author)
- “Funds Face New Sanctions, AML Risks in Wake of Escalating U.S.–Russia Tensions,” Schulte Alert, April 4, 2014 (co-author)
- “FinCEN Issues Final Rules Relating to Money Services Business (MSB) Definitions,” Journal of Investment Compliance, April 2012 (co-author)
- “Recent FCPA Developments Highlight Risk of Individual Liability,” Financial Fraud Law Report, March 2012 (co-author)
- “The FCPA and AML Statutes: Prosecutors Increasingly Combining Charges, to Great Effect,” Business Crimes Bulletin, January 2012 (co-author)
- “The FCPA and AML Statutes: The Prosecutor’s Combined Weapon of Choice,” Business Crimes Bulletin, December 2011 (co-author)
- “Government Launches FCPA Inquiry into Investments by Sovereign Wealth Funds in U.S. Banks and Private Equity Firms,” Financial Fraud Law Report, July/August 2011 (co-author)
- “SEC Extends and Modifies Its No-Action Relief for BDs to Rely on RIAs for Performance of CIP” (Complinet), March 8, 2011 (co-author)
- “FinCEN and Regulators Issue Joint Guidance on Obtaining Beneficial Ownership Information, Potentially Expanding Certain Financial Institutions’ USA PATRIOT Act Obligations,” Journal of Investment Compliance, Nov. 22, 2010
- “FinCEN and SEC Sanction Broker-Dealer and Chief Compliance Officer for AML Deficiencies Relating to Foreign Sub-Accounts” (Complinet), Oct. 6, 2010
- “Bribery Act 2010,” The Hedge Fund Journal, September 2010 (co-author)
- “Practice Note: Developing an Effective AML Compliance Program for Hedge Funds” (Complinet), Feb. 12, 2008
- “The Foreign Corrupt Practices Act: Recent Cases and Enforcement Trends,” Journal of Investment Compliance, Vol. 8, No. 3, 2007 (co-author)
- “Ask Not For Whom the Bell Tolls, It May Toll For You Next: Intensified Anti-Money Laundering Enforcement Transforms the Regulatory Landscape,” Journal of Investment Compliance, Vol. 6, No.1, Fall 2005
- “AML Programs for Financial Institutions Under Section 352 of the USA Patriot Act,” Banking & Financial Services Policy Report, Vol. 21, No. 7, July 2002
- “Anti-Money Laundering Provisions of the USA PATRIOT Act of 2001,” CCH, April 2002
- “Are Self Regulatory Organizations State Actors? Two Recent Cases Take Contrasting Perspectives,” The Journal of Investment Compliance, Vol. 2, No. 1, Summer 2001
- “2001: A Money Laundering Space Odyssey,” Securities Industry Association Compliance and Legal Seminar on SIA Website, March 2001
- “Did Bankers Trust Alter The Rules?,” New York Law Journal, Corporate Counsel, at S4, Nov. 20, 2000
- “How Safe Is The Bank Secrecy Act Safe Harbor?,” Journal of Investment Compliance, Vol. 1, No. 2, Fall 2000
- “International Ramifications of U.S. Anti-Money Laundering Policy: Whose Law is the United States Enforcing?,” Journal of International Banking Law, Vol. 15, Issue 4/5, April/May 2000
- “Back to the Future: How Recent Events Have Revived the Call for More Stringent Anti-Money Laundering Regulation,” Banking Policy Report, Vol. 19, No. 6, March 20, 2000
- “Money Laundering In The Millennium: A Broker-Dealer’s Guide To KYC, SAR & OFAC,” Securities Industry Association Compliance and Legal Division Annual Seminar on SIA Website, March 2000
- “Money Laundering and Suspicious Activity Reporting: Now What’s a Broker-Dealer To Do?,” Money Laundering Alert, April-July 1999 (published in four parts)
- “Never a Dull Moment: Hot Topics in AML and Financial Crimes,” SIFMA Anti-Money Laundering & Financial Crimes Conference, May 2023
- Fordham Law Women's Fifth Annual Symposium, March 2023
- “Industry Hot Topics,” SIFMA Anti-Money Laundering & Financial Crimes Conference, May 2022
- FIA Law & Compliance Division Conference, April 2021
- “Financial Crimes Case Studies: You Make the Call!,”SIFMA Anti-Money Laundering & Financial Crimes Conference, Feb. 2021
- “Confusion Worse Confounded: AML in the Capital Markets,” SIFMA Anti-Money Laundering & Financial Crimes Conference, New York, February 2019
- “Hot Topics: AML, Cybersecurity, Privacy, GDPR,” FIA Law & Compliance Division 40th Annual Law & Compliance Division Conference, Washington DC, May 2018
- “Shells and Pillars: Are You Ready?,” SIFMA Anti-Money Laundering & Financial Crimes Conference, New York, February 2018
- “DFS, State, and OFAC Officials Weigh-In on Regulatory Hot Buttons Governing the Insurance and Reinsurance Industries,” 8th Annual Forum on AML & OFAC Compliance for the Insurance Industry, January 2018
- “Developments in AML – What’s New?,” FIA Law & Compliance Division 39th Annual Law & Compliance Conference on the Regulation of Futures, Derivatives and OTC Products, May 2017
- “Crisis Management and Reactions to Breaking Events,” SIFMA 17th Annual Anti-Money Laundering & Financial Crimes Conference, February 2017
- “Regulatory and Enforcement Roundtable: Perspectives from Federal and State Agencies that Govern the Insurance and Reinsurance Industries,” ACI 7th Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2017
- “What to Do When You Suspect a Violation? Tips for Internal Investigations and Determining the Value of a Voluntary Self-Disclosure,” ACI 7th Annual New York Forum on Economic Sanctions, December 2016
- “A Financial Institution Under Criminal Investigation – Strategic Issues,” Deloitte Tenth Annual AML Conference, October 2016
- “Sanctioning Compliance Officers: External and Internal Sanctions on Compliance Officers,” NYU Law Compliance: New Risks, Challenges, and Approaches Conference, October 2016
- “Customer Due Diligence in a Global AML Environment,” SIFMA 16th Annual Anti-Money Laundering & Financial Crimes Conference, April 2016
- Co-Moderator, “Regulatory and Enforcement Roundtable: Perspectives from OFAC, the Department of State, the DOJ, and Other Federal and State Agencies That Govern the Insurance and Reinsurance Industries,” ACI 6th Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2016
- “Meeting Government’s Expectations: How Much Is Enough Due Diligence to Protect Your Organization?,” ACI 6th Annual Economic Sanctions Bootcamp, December 2015
- “AML Compliance: Hot Topics,” SIFMA Compliance & Legal Society Annual Seminar, March 2015
- “Compliance Officers and Personal Liability: Are You At Risk?,” ACAMS Webinar, March 2015
- “Lessons Learned from Enforcement,” SIFMA 15th Annual Anti-Money Laundering & Financial Crimes Conference, February 2015
- Co-Moderator, “Regulatory and Enforcement Roundtable: Perspectives from the Department of State, the Office of the New York State Attorney General, the Secret Service, and Other Federal and State Agencies That Govern the Insurance and Reinsurance Industries,” ACI 5th Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2015
- “Know Your Product: Money Laundering Risks in New and Complex Products,” ABA Money Laundering Enforcement Conference, November 2014
- “Current Regulatory and International Issues,” FIA Law & Compliance Regulatory Roundup: A Mid-Year Review for Chicago Members, September 2014
- “AML Compliance: Hot Topics,” SIFMA Compliance and Legal Society Annual Seminar, April 2014
- Moderator, “AML and Beyond: The Intersection of AML, Anti-Corruption and Sanctions,” SIFMA 14th Annual Anti-Money Laundering and Financial Crimes Conference, January 2014
- Co-Moderator, “Regulatory and Enforcement Roundtable: Perspectives from the Department of State, the DOJ, the U.S. Attorney’s Office, the Office of the New York State Attorney General, and Other Federal and State Agencies That Govern the Insurance Industry,” ACI 4th Annual Forum on AML & OFAC Compliance for the Insurance Industry, January 2014
- Co-Chair, ACI 4th Economic Sanctions Boot Camp, December 2013
- “AML Compliance — Hot Topics,” SIFMA Compliance and Legal Society Annual Seminar, March 2013
- Moderator, “Significant Sanctions Enforcement Actions and Other Financial Crime Developments,” SIFMA 13th Annual Anti-Money Laundering & Financial Crimes Conference, February 2013
- “Beneficial Ownership: Will A Risk-Based Approach Survive?” and “Broker Dealer & Wealth Management,” FIBA 13th Annual Anti-Money Laundering Compliance Conference, February 2013
- Moderator, “Conducting Effective Internal Investigations into Potential Money Laundering, Fraud, Sanctions Violations, or FCPA Violations,” ACI 3rd Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2013
- “The Aftermath of the $619 Million ING Case, and What It Says About Sanctions Penalty Calculations: Mitigating and Aggravating Factors for Financial Institutions, Non-Regulated Entities and Individuals,” ACI OFAC Boot Camp, December 2012
- “Regulatory Investigations,” PLI Bet the Company Litigation, September 2012
- “Enforcement Against Regulated Financial Institutions,” ACI 5th Advanced Forum on OFAC Enforcement and Compliance, April 2012
- “Securities Focus: Reverse Mergers, Penny Stock and Micro-Cap Securities Fraud — What are the AML Risks and Regulatory Expectations?,” ACAMS 17th Annual International Anti-Money Laundering Conference, March 2012
- “AML Compliance — Hot Topics,” SIFMA 2012 Compliance and Legal Society Annual Seminar, March 2012
- “Ten Years After 9/11: A Retrospective On How We Got Here” and “‘Who's On First?’ – Managing the Allocation of AML Responsibilities in a New Regulatory Environment,” SIFMA 12th Annual Anti-Money Laundering and Financial Crimes Conference, February 2012
- “Conducting Internal Investigations into Potential Money Laundering, Sanctions Violations, or FCPA Violations,” ACI 2nd Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2012
- “Assessing the Price of Sanctions Violations by U.S. and Non-U.S. Entities, and Individuals: The Agencies’ Approach to Global Investigations, Enforcement and Penalty Calculations,” ACI OFAC Boot Camp, December 2011
- “Gifts, Entertainment & Hospitality in High Risk Markets — A Practical Guide on What You Can and Can’t Do,” ACI 26th National Conference on the Foreign Corrupt Practices Act, November 2011
- “AML Monitoring,” SEC Roundtable on Microcap Securities, October 2011
- “Focus on Securities: Creating Optimal Customer Surveillance Programs” and “Combating Consistent Anti-Money Laundering Challenges: Topical Discussions With Subject Matter Experts,” ACAMS 10th Annual International Anti-Money Laundering Conference, September 2011
- “AML Compliance: Hot Topics,” SIFMA Compliance & Legal Society Annual Seminar, March 2011
- “Regulatory and Enforcement Roundtable,” ACI AML and OFAC, January 2011
- “AML, FCPA and OFAC: The Intersection of Three Key Risk Areas,” Schulte 20th Annual Private Investment Funds Seminar, January 2011
- “Fundamentals of FCPA Compliance: The Foreign Corrupt Practices Act Demystified,” ACI 24th Global Conference on the Foreign Corrupt Practices Act, November 2010
- “Practical Approach to Combating Consistent Anti-Money Laundering Challenges,” ACAMS 9th Annual International Anti-Money Laundering Conference, September 2010
- “AML Compliance — Current Issues,” SIFMA CL 2010 Annual Seminar, May 2010
- Moderator, “Regulator Panel — Keeping Current With Regulatory Developments to Ensure Your Institution Remains Compliant,” SIFMA 10th Annual Anti-Money Laundering Conference, March 2010
- “FCPA,” Deloitte Third Annual AML Compliance Conference, November 2009
- “Enforcement Actions — Monitoring,” ACAMS/Morgan Stanley, October 2009
- Moderator, “Regulators Insights: Avoid Penalties and Optimize Your Firm's Defense by Complying With the Latest AML and Fraud Regulations” and “Managing Compliance Requirements for Clearing and Introducing Firms in an Era of Increased Scrutiny and Reduced Resources,” 19th Annual AMLAC & Fraud Forum, October 2009
- “Money Laundering and Asset Forfeiture,” ABA’s 23rd Annual National Institute on White Collar Crime, March 2009
- SIFMA Annual Anti-Money Laundering Conference, 2001–10
- “Q&A Session: ‘Ask the Regulators’,” 2nd Annual Anti-Money Laundering & Counter-Terrorist Financing Forum, November 2007
- SIFMA Law & Compliance Division Annual Seminar, 1987–2010
- SIFMA Compliance & Legal Division Mid-Year Compliance Conference, 2004–06
- Co-chair, Institutional Investor’s Anti-Money Laundering and Counter-Terrorist Financing Forum, 2005-06
- “AML Guidance for Investment Advisors,” Investment Management Compliance Summit, September 2006
- FIA Law and Compliance Seminar, 2002–06
- Institute for International Research on Bank Secrecy Act and Anti-Money Laundering, 1996-2005 (Co-chair of program 1999–05)
- Co-chair, ICM Conference on Money Laundering, 1999–2002
- Member, Board of Directors of National Organization of Italian American Women, 2009–Present;
- Chair, 2012–2014
- Chair Elect, 2012
- Vice Chair, 2009–2011
- Former Member, Editorial Board of Complinet
- Member, Board of Trustees of Federal Bar Council Foundation, 1997–2003; 2005–2008; 2012–2019
- Member, Fordham Law Alumni Association, Board of Directors, 1997–Present
- Member, New York City Bar Association, Federal Courts Committee, 1993–1994
- Division Co-director, ABA Litigation Committee, 1991–1992
- Chair/Co-chair, ABA Securities Litigation Committee, 1989–1991
- Chair, Broker/Dealer Sub-Committee of Litigation Committee, 1987–1989
- Member, ABA White Collar Crime Committee, 1993–Present
- Secretary, New York Women's Bar Association, 1976–1977
- Founder, Fordham Law Women, 1972
- Professional Activities
- Securities Industry and Futures Industry Representative, U.S. Treasury Department Bank Secrecy Act Advisory Group, 1995–2008
- Member, SIFMA Anti-Money Laundering and Financial Crimes Committee, 2014–Present; Counsel, 2000–2014
- Member of U.S. Delegation to FATF, October 2002
- Chair, Ad Hoc Securities Industry Group on Bank Secrecy Act and Anti-Money Laundering, 1995–2000
- U.S. Securities Industry Representative, Financial Action Task Force, 1998
- The Best Lawyers in America
- Ethisphere: Attorneys Who Matter
- Expert Guide to the World’s Leading White Collar Crime Lawyers
- Expert Guide to the World’s Leading Women in Business Law (White Collar Crime)
- Who's Who Legal: Business Crime Defence
- The Legal 500 US
- New York Super Lawyers
- Top Women Attorneys in the New York Metro Area
- 2014 Recipient, SIFMA Award in recognition of extraordinary contributions to the Anti-Money Laundering and Financial Crimes Committee
- 2011 Recipient, Highly Commended Award, Emerald Literati Network
- 2009 Recipient, NOW-NYC Women of Power & Influence Award
- 2008 Recipient, Burton Award for Distinguished Legal Writing for article titled "The Foreign Corrupt Practices Act: Recent Cases and Enforcement Trends"
- 2006 Recipient, Outstanding Paper Award, Emerald Literati Network
- 1998 Recipient, Director's Medal for Exceptional Service, Financial Crimes Enforcement network of the United States Treasury Department
- 1988 Recipient, YWCA Women of Achievement Award
- Merrill Lynch Pierce Fenner and Smith Inc., 1983-1997
- First Vice President and Assistant General Counsel
- U.S. Attorney’s Office, Southern District of New York, 1977-1983
- Assistant U.S. Attorney
- Fordham University School of Law, 1982-1984, 2003
- Adjunct Professor of Law
- Martin, Obermaier & Morvillo, 1974–1976
- Associate
Betty Santangelo
Focuses on white-collar criminal defense and securities/bank enforcement.
A former Assistant US Attorney for the Southern District of New York, she concentrates in securities and commodities fraud prosecutions. She represents financial institutions (banks, broker-dealers, mutual funds, FCMs, insurance companies, investment advisers, hedge funds and private equity funds), other corporate entities and individuals in matters brought by the U.S. Attorneys’ offices, by various regulatory agencies, including the SEC, the bank regulatory agencies, the CFTC, FINRA, international regulators and state and local prosecutors.
Betty also has significant experience conducting internal investigations for these entities. In addition, she has served as an independent consultant in SEC enforcement matters examining both the NYSE and a regional broker-dealer.
Before joining Schulte, Betty served as First Vice President and Assistant General Counsel for Merrill Lynch, where she managed the firm's securities and criminal regulatory investigations group and represented the firm and its employees in enforcement proceedings before federal and state regulatory agencies, and in criminal matters before U.S. Attorneys' offices and state prosecutors, as well as in foreign jurisdictions.
She has also served as Division Director of the ABA Litigation Committee and Chair of its Securities Litigation and Broker-Dealer Subcommittees.
She has contributed a chapter on “Representation Prior to Indictment” in the book Defending Federal Criminal Cases: Attacking the Government’s Proof (Law Journal Press, 2009, 2015, 2021), co-authored the “Civil and Criminal Enforcement” chapter of the Insider Trading Law and Compliance Answer Book (Practising Law Institute, 2011–2020) and contributed two chapters in Broker Dealer Regulation (Practising Law Institute, 2009–2010, 2014–2020).
Betty is recognized as a leading lawyer by The Legal 500 US, The Best Lawyers in America, Ethisphere: Attorneys Who Matter, Expert Guide to the World’s Leading White Collar Crime Lawyers, Expert Guide to the World’s Leading Women in Business Law, Who's Who Legal: Business Crime Defence and New York Super Lawyers. She was also presented with the New York Chapter of the National Organization for Women's annual Women of Power and Influence Award.
Nationally recognized for her deep experience in corporate compliance issues, including anti-money laundering, OFAC and FCPA, Betty’s representation of financial institutions in white collar and regulatory matters frequently draws on these areas of experience, including advising financial institutions on their anti-money laundering/OFAC/FCPA procedures. At Merrill Lynch, she was also responsible for oversight of all Bank Secrecy Act reporting and anti-money laundering activities, and the implementation of Merrill Lynch’s anti-money laundering procedures.
Among her many professional activities, she has served as the Securities and Futures Industry’s representative on the Bank Secrecy Act Advisory Group of the U.S. Department of the Treasury. Betty also is a founding member of and has served as counsel to the Securities Industry and Financial Markets Association’s (SIFMA) Anti-Money Laundering and Financial Crimes Committee. In 2014, she was honored by SIFMA for her extraordinary contributions to the committee and recognized for her dedication to improving industry compliance.
In 1998, the Financial Crimes Enforcement Network of the US Treasury Department awarded Betty its Director’s Medal for Exceptional Service. That same year, she represented the U.S. securities industry at the Financial Action Task Force (“FATF”) meeting in Brussels, Belgium. In 2002, she represented SIFMA, the Futures Industry Association and the Investment Company Institute at the FATF meeting in Paris.
Betty is a former adjunct professor at Fordham Law School, where she taught a course on money laundering and founded Fordham Law Women to raise awareness of the issues faced by women in the law school community. In 2019, Fordham Law established the Betty Santangelo Award to recognize alumnae working to advance the careers of women in the legal industry.
She is a much sought-after speaker on corporate compliance, anti-money laundering/OFAC/FCPA, white collar criminal and securities law issues, including at SIFMA, the FIA, ACAMS, the ABA/ABA AML conference and FIBA.
From the Emerald Literati Network, she received an “outstanding paper” award in 2006 for an article she wrote on money laundering enforcement actions and a “highly commended” award in 2011 for an article she wrote on beneficial ownership information and USA PATRIOT Act obligations.
In 2008, she won a Burton Award, which recognizes exceptional legal writing, for an article she wrote on the FCPA. She is a recipient of the YWCA Woman of Achievement award, as well as other awards.
Bar Admissions
- New York
- Florida
Court Admissions
- US Supreme Court, 2013
- US District Court, Eastern District of New York, 1975
- US District Court, Southern District of New York, 1975
- US Court of Appeals, Second Circuit, 1975
Clerkships
- Hon. Vincent L. Broderick, US District Court, Southern District of New York
Education
- Fordham University School of Law, JD
- Trinity College, BA
- University of Oxford, Honors Program
- Involved in numerous representations of large banks and broker-dealers in connection with possible AML/BSA violations before the SEC, FINRA, the bank regulators and FinCEN.
- Conducting internal investigation into possible money laundering and foreign tax fraud by foreign institutional client of U.S. commercial bank.
- Representation of global financial institution in international money laundering investigation.
- Representation of major securities firm in parallel N.Y. District Attorney’s Office, SEC and federal grand jury investigations into possible Martin Act violations, securities fraud, tax evasion and money laundering.
- Independent consultant retained to review the NYSE’s rules, practices and procedures applicable to floor members.
- Representation of foreign banks before OCC in connection with negotiation of settlement agreement and examination by SEC.
- Advise large private equity funds and private investment funds in connection with establishing of AML/sanctions programs.
Books/Treatises
- “Civil and Criminal Enforcement,” Insider Trading Law and Compliance Answer Book (Practising Law Institute), 2011–2020
- Private Equity Funds: Formation and Operation (Practising Law Institute) (contributor)
- Hedge Funds: Formation, Operation and Regulation (ALM Law Journal Press) (contributor)
- “Representation Prior to Indictment,” Defending Federal Criminal Cases: Attacking the Government's Proof (Law Journal Press), 2009, 2015, 2021 (co-author)
- “Anti-Money Laundering Regulations Applicable to Broker-Dealers,” Broker Dealer Regulation (Practising Law Institute), September 2014
- “Anti-Money Laundering,” Practitioner’s Guide for Broker-Dealers (Complinet), Nov. 11, 2010 (co-author)
- “Clearing Broker Liability and Responsibilities,” Broker Dealer Regulation (Practising Law Institute),May 2010 (co-author)
- “Specific Corporate Compliance Challenges by Practice Area: Anti-Money Laundering,” The Corporate Compliance Practice Guide: The Next Generation (Matthew Bender/LexisNexis), 2009 (co-author)
- “Anti-money Laundering Regulation of Broker-Dealers,” Broker Dealer Regulation, Chapter 18, June 2009 (co-author)
- “Mutual Fund Compliance and the Anti-Money Laundering Regulatory Regime, Part I and II,” The Review of Securities & Commodities Regulation, September 2005 and September 2007
- “The Anti-Money Laundering Regime for the Futures Industry,” The Review of Securities & Commodities Regulation, March 2007
- “Suitability in Cyberspace,” Securities & Commodities Regulation, Vol. 34, No. 11, June 13, 2001
- “The Foreign Corrupt Practices Act and Money Laundering,” Conducting Due Diligence (Practising Law Institute), May 1999
- “Money Laundering and Suspicious Activity Reporting,” Securities and Commodities Regulation, Vol. 31, No. 15, Sept. 9, 1998
Articles
-
“FinCEN Issues Final Rule Requiring AML Reporting for Real Estate Sector,” Schulte Alert, Nov. 5, 2024
- “The Corporate Transparency Act: Filing Deadline Fast Approaching,” Schulte Alert, Oct. 22, 2024
- “FinCEN Issues Final AML/CFT Program Rule for Certain Investment Advisers,” Schulte Alert, Sept. 30, 2024
- “FinCEN Issues Proposed Rule to Strengthen and Modernize AML/CFT Programs for Financial Institutions,” Schulte Alert, Aug. 16, 2024
- “Sanctions Update: Statutory Amendments and an Interim Final Rule Create Significant Implications for OFAC Sanctions Compliance,” Schulte Alert, June 11, 2024
- “FinCEN Issues Proposed Rule Requiring Customer Identification Programs for Investment Advisers,” Schulte Alert, June 11, 2024
- “FinCEN Issues Proposed Rule to Implement AML Reporting Requirements for Real Estate Sector,” Schulte Alert, May 3, 2024
- “Sanctions Update: OFAC Re-Emphasizes Applicability of Sanctions to Non-US Persons,” Schulte Alert, April 4, 2024
- “FinCEN Once Again Proposes Anti-Money Laundering Program Requirements for Investment Advisers,” Schulte Alert, March 18, 2024
- “Corporate Transparency Act Update: Federal District Court Rules the Act Unconstitutional,” Schulte Alert, March 5, 2024
- “Corporate Transparency Act Update: Beneficial Ownership Reporting Rule Now Effective and FinCEN Is Accepting Reports,” Schulte Alert, Jan. 4, 2024
- “The Corporate Transparency Act: Final Rule on Access to Beneficial Ownership Information,” Schulte Alert, Jan. 2, 2024
- “Anti-Money Laundering Update: Treasury to Re-Propose Long Anticipated AML Program Rules Aimed at Hedge Funds, PE Funds and Certain Investment Advisers,” Schulte Alert, Dec. 22, 2023
- “The Corporate Transparency Act: FinCEN Extends Filing Deadline From 30 to 90 Days For Reporting Companies Created or Registered in 2024,” Schulte Alert, Dec. 1, 2023
- “CFPB Proposes Rule Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications,” Schulte Alert, Nov. 16, 2023
- “California Passes Portions of the Model Money Transmission Modernization Act,” Schulte Alert, Oct. 12, 2023
- “Key Takeaways From Agencies’ Tri-Seal Compliance Note,” Law360, Aug. 25, 2023
- “SEC Exam Staff Issues Alert Highlighting Deficiencies in Broker-Dealers’ AML Programs,” Schulte Alert, Aug. 25, 2023
- “Sanctions Update: OFAC Encourages Voluntary Self-Disclosure for Sanctions Violations,” Schulte Alert, Aug. 2, 2023
- “What To Note In FinCEN, DOJ Action Against Crypto Exchange,” Law360, April 18, 2023
- “Alumnae Founders of Groups for Women and Black Students Speak at Fordham Law Women Symposium,” Fordham Law News, April 4, 2023 (quoted)
- Securities Enforcement Quarterly, Schulte Publication, February 2023
- “FinCEN Issues Proposed Access Rule and Proposed Forms to Further Implement the CTA,” Schulte Alert, Feb. 7, 2023
- “FinCEN Identifies Bitzlato as a 'Primary Money Laundering Concern' in First-Time Use of Section 9714(a) and DOJ Charges Its Founder with Owning an Unlicensed Money Transmitting Business,” Schulte Alert, Feb. 3, 2023
- “NYDFS Releases Guidance for BitLicensees and Limited Purpose Trust Companies on Asset Custody in the Wake of Cryptocurrency Insolvencies,” Schulte Alert, Jan. 31, 2023
- “NYDFS Announces $100 Million Settlement with Coinbase for AntiMoney Laundering Compliance Deficiencies,” Schulte Alert, Jan. 23, 2023
- “AML Recent Developments: What Practitioners Need to Know,” The Review of Securities & Commodities Regulation, Nov. 9, 2022
- “FinCEN Issues Final Rule Requiring Reporting of Beneficial Ownership Information,” Schulte Alert, Oct. 20, 2022
- Securities Enforcement Quarterly, Schulte Publication, August 2022
- “Russian Sanctions Update: OFAC Issues Broad Restrictions on ‘New Investment’ in Russia,” Schulte Alert, June 10, 2022
- Securities Enforcement Quarterly, Schulte Publication, May 2022
- “Russian Sanctions Update: FinCEN and NYDFS Issue Guidance,” Schulte Alert, April 25, 2022
- “Sanctions Update: US Imposes Sweeping Sanctions Against Russia and Belarus,” Schulte Alert, Feb. 28, 2022
- “Sanctions Update: US Begins to Roll Out Sanctions Against Russia,” Schulte Alert, Feb. 23, 2022
- “FinCEN Commences Rulemaking Process to Implement AML Reporting Requirements for Real Estate Sector,” Schulte Alert, Feb. 11, 2022
- Securities Enforcement Quarterly January 2022, Schulte Publication, Jan. 2022
- “FinCEN Issues Notice of Proposed Rulemaking Regarding Beneficial Ownership Information Reporting Requirements Under the Corporate Transparency Act,” Schulte Alert, Jan. 14, 2021
- “US Expands Sanctions Against Belarus, Barring New Sovereign Debt Transactions,” Schulte Alert, Dec. 10, 2021
- Securities Enforcement Quarterly, Schulte Publication, October 2021; republished in the Harvard Law School Forum on Corporate Governance, November 2021
- “FATF Releases Anticipated Guidance for Virtual Assets and Virtual Asset Service Providers, Survey Results on Cross-Border Payments and Proposed Revisions to Beneficial Ownership Standard,” Schulte Alert, Nov. 30, 2021
- “Treasury Issues Reports and Guidance to Assist Industry In Addressing Threats Posed by Certain Virtual Currency Transactions and Ransomware Payments,” Schulte Alert, Oct. 28, 2021
- “FinCEN Issues First National AML/CFT Priorities and Defers Implementation of Priorities and No-Action Letter Process to Future Rulemakings,” Schulte Alert, July 12, 2021
- Securities Enforcement Quarterly, Schulte Publication, July 2021
- “Federal Banking Regulators Update Guidance on Model Risk Management Practices for AML and Sanctions Compliance,” Schulte Alert, June 10, 2021
- “White House Revamps Chinese Securities Trading Ban,” Schulte Alert, June 8, 2021
- Securities Enforcement Quarterly, Schulte Publication, April 2021
- “FinCEN Commences Rulemaking Process for Implementation of Corporate Transparency Act Requiring Disclosure of Beneficial Ownership Information,” Schulte Alert, April 26, 2021; republished in the Harvard Law School Forum on Corporate Governance, May 11, 2021
- “Broker-Dealers and Mutual Funds: Increased Regulatory Focus on Suspicious Activity Monitoring and Reporting Requirements,” Schulte Alert, April 1, 2021
- “US Sanctions on Chinese Company Securities: Further Developments,” Schulte Alert, Jan. 19, 2021
- “Passage of Anti-Money Laundering Act of 2020 Includes Comprehensive BSA/AML Reform Measures,” Schulte Alert, Jan. 7, 2021
- “OFAC Provides Guidance on Trading Ban in Chinese Companies,” Schulte Alert, Dec. 31, 2020
- “FinCEN Releases Notice of Proposed Rulemaking and FAQs Concerning Convertible Virtual Currency and Legal Tender Digital Asset Transactions,” Schulte Alert, Dec. 23, 2020
- “SEC Staff Bulletin Highlights AML Risks Associated with Low-Priced Securities Trading in Omnibus Accounts,” Schulte Alert, Dec. 14, 2020
- “Treasury Issues Advisories Related to Ransomware Attacks,” Schulte Alert, Dec. 1, 2020
- “White House Bans Trading in 31 Chinese Companies,” Schulte Alert, Nov. 13, 2020
- “AML Managers Question FinCEN’s New Effectiveness Test,” FinOps Report, Oct. 7, 2020 (quoted)
- “FinCEN and Banking Agencies Provide Clarification on PEP Screening Best Practices,” Schulte Alert, Oct. 5, 2020
- “AML Update: FinCEN Issues First-Ever Enforcement Guidelines and Federal Banking Agencies Update Enforcement Guidance,” Schulte Alert, Sept. 2, 2020; republished in The Banking Law Journal, February 2021
- “Sanctions Update: OFAC Regulations, Advisories and Enforcement Actions: November 2019 through July 2020,” Schulte Alert, August 7, 2020; republished in The Hedge Fund Journal, September 2020
- “Sanctions Update: US Sanctions Compliance During COVID-19,” Schulte Alert, April 24, 2020
- “US Government Continues to Penalize Unauthorized Disclosures of Suspicious Activity Reports,” Schulte Alert, Feb. 24, 2020
- “Mitigating OFAC Risks in Mergers and Acquisitions,” Schulte Alert, Feb. 3, 2020; republished in Thomson Reuters Westlaw Journal Bankruptcy, March 24, 2020
- “Sanctions Update: DOJ Revises Voluntary Self-Disclosure Policy for Export Control and Sanctions Violations,” Schulte Alert, Jan. 2, 2020
- “OFAC Expands Reporting Obligations and Highlights Importance of Cooperation,” Schulte Alert, Nov. 21, 2019; republished in The Hedge Fund Journal, February 2020
- “Sanctions Update: Iran, Venezuela, Ukraine, Nicaragua and Cuba,” Schulte Alert, Oct. 11, 2019 (co-author)
- “Federal Banking Regulators Issue Joint Statement on BSA/AML Compliance Program Examinations,” Schulte Alert, August 1, 2019 (co-author)
- “OFAC Update: A Framework for Compliance and Recent Settlements,” Schulte Alert, July 12, 2019 (co-author); republished in The Hedge Fund Journal, August 2019
- “FinCEN Assesses Civil Money Penalty Against P2P Currency Exchanger for BSA Violations,” Schulte Alert, April 26, 2019 (co-author)
- “Sanctions Update: Venezuela,” Schulte Alert, April 4, 2019 (co-author)
- “Sanctions Update: OFAC Sanctions Venezuela’s State-Owned Oil Company,” Schulte Alert, Feb. 8, 2019 (co-author)
- “Federal Banking Regulators Issue Joint Statement Encouraging Innovation in BSA/AML Compliance,” Schulte Alert, Dec. 5, 2018 (co-author)
- “Sanctions, Sanctions and More Sanctions!” The Hedge Fund Journal, December 2018 (co-author)
- “Sanctions Update: Iran, Venezuela and Russia,” Schulte Alert, Nov. 13, 2018 (co-author)
- “Arrest of FinCEN Employee for Unlawful Disclosure of SARs and SAR Information,” Schulte Alert, Oct. 19, 2018 (co-author)
- “FinCEN and Federal Banking Agencies Issue Statement on Pooling Resources for BSA Compliance,” Schulte Alert, Oct. 5, 2018 (co-author)
- “Sanctions Update: Iran, Global Magnitsky and Sudan,” Schulte 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,” Schulte Alert, June 4, 2018 (co-author)
- “OFAC Focuses on Oligarchs, Adds Sanctions on Russian Persons and Entities,” Schulte Alert, April 26, 2018 (co-author)
- “NYDFS Issues Guidance to Deter Fraud and Manipulation in Virtual Currency Markets,” Schulte Alert, Feb. 9, 2018 (co-author)
- “Treasury Identifies Russian Political Figures and Oligarchs,” Schulte Alert, Feb. 1, 2018 (co-author)
- “Sanctions and AML Update: North Korea and Venezuela,” Schulte Alert, Sept. 27, 2017 (co-author); republished in The Hedge Fund Journal, October 2017
- “Sanctions Update: U.S. Imposes Immediate Restrictions Relating to Venezuelan Securities,” Schulte Alert, Aug. 28, 2017 (co-author)
- “Sanctions Update: Russia, Iran, North Korea and Venezuela,” Schulte Alert, Aug. 2, 2017 (co-author); republished in The Hedge Fund Journal, August 2017
- “FinCEN Issues Assessment Against Virtual Currency Exchange — the First Enforcement Action Against a Foreign-Located Money Services Business,” Schulte Alert, July 27, 2017 (co-author); republished in PaymentsJournal, Aug. 14, 2017
- “FinCEN Renews GTOs Targeting Real Estate Transactions,” Schulte Alert, March 1, 2017 (co-author)
- “FinCEN Issues Suspicious Activity Report Guidance Concerning Cybersecurity,” Schulte Alert, Nov. 1, 2016 (co-author)
- “DOJ and OFAC Take Enforcement Action Against Canadian Payment Processor,” Schulte 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,” Schulte Alert, July 6, 2016 (co-author); republished in Westlaw Journal — Bank & Lender Liability, Sept. 19, 2016
- “US Eases Sanctions on Burma,” Schulte Alert, May 31, 2016 (co-author)
- “Highlights of FinCEN’s Long-Awaited Customer Due Diligence Final Rule,” Schulte Alert, May 11, 2016 (co-author); republished in The Hedge Fund Journal, June 2016
- “OFAC and BIS Amend Cuba Sanctions Regulations,” Schulte Alert, Feb. 1, 2016 (co-author)
- “New AML Regulatory Initiative Targets Real Estate Industry,” Schulte 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,” Schulte Alert, Jan. 20, 2016 (co-author); republished in Business Crimes Bulletin, June 2016
- “NYDFS Proposes New AML/Sanctions Programs and Annual Certification Requirements for Banks, Money Transmitters and Check Cashers,” Schulte Alert, Dec. 4, 2015 (co-author)
- “The New AML Rules: Implications for Private Fund Managers,” Schulte 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)
- “BHP Billiton Settles with SEC for $25 Million for Providing Foreign Officials with Luxury Travel to Olympics,” Schulte Alert, May 21, 2015 (co-author)
- “PayPal Settlement Highlights OFAC Risks for Money Services Businesses,” Schulte Alert, March 27, 2015 (co-author)
- “Federal and State Regulators Target Compliance Officers,” Schulte Alert, Feb. 20, 2015 (co-author)
- “Sanctions Update: Crimea,” Schulte Alert, Feb. 5, 2015 (co-author); republished in Westlaw Journal – Securities Litigation & Regulation, March 5, 2015
- “FinCEN’s Much Anticipated Proposed Rule on Customer Due Diligence Is Finally Here,” Financial Fraud Law Report, November/December 2014 (co-author)
- “Sanctions Update: Sectoral Sanctions Against Russia Escalate,” Schulte Alert, Sept. 18, 2014 (co-author); republished in Westlaw Journal – Securities Litigation & Regulation, Oct. 16, 2014
- “FinCEN’s Much-Anticipated Proposed Rule on Customer Due Diligence Is Finally Here,” Schulte Alert, Aug. 8, 2014 (co-author)
- Schulte Insider Trading Developments Newsletter, Summer 2014 (contributor)
- “Threatened Sectoral Sanctions Against Russia Become Reality,” Schulte Alert, July 30, 2014 (co-author)
- “Escalating U.S.–Russia Tensions Lead to New Sanctions, Heightened AML Risks,” Schulte Alert, April 4, 2014 (co-author)
- “Funds Face New Sanctions, AML Risks in Wake of Escalating U.S.–Russia Tensions,” Schulte Alert, April 4, 2014 (co-author)
- “FinCEN Issues Final Rules Relating to Money Services Business (MSB) Definitions,” Journal of Investment Compliance, April 2012 (co-author)
- “Recent FCPA Developments Highlight Risk of Individual Liability,” Financial Fraud Law Report, March 2012 (co-author)
- “The FCPA and AML Statutes: Prosecutors Increasingly Combining Charges, to Great Effect,” Business Crimes Bulletin, January 2012 (co-author)
- “The FCPA and AML Statutes: The Prosecutor’s Combined Weapon of Choice,” Business Crimes Bulletin, December 2011 (co-author)
- “Government Launches FCPA Inquiry into Investments by Sovereign Wealth Funds in U.S. Banks and Private Equity Firms,” Financial Fraud Law Report, July/August 2011 (co-author)
- “SEC Extends and Modifies Its No-Action Relief for BDs to Rely on RIAs for Performance of CIP” (Complinet), March 8, 2011 (co-author)
- “FinCEN and Regulators Issue Joint Guidance on Obtaining Beneficial Ownership Information, Potentially Expanding Certain Financial Institutions’ USA PATRIOT Act Obligations,” Journal of Investment Compliance, Nov. 22, 2010
- “FinCEN and SEC Sanction Broker-Dealer and Chief Compliance Officer for AML Deficiencies Relating to Foreign Sub-Accounts” (Complinet), Oct. 6, 2010
- “Bribery Act 2010,” The Hedge Fund Journal, September 2010 (co-author)
- “Practice Note: Developing an Effective AML Compliance Program for Hedge Funds” (Complinet), Feb. 12, 2008
- “The Foreign Corrupt Practices Act: Recent Cases and Enforcement Trends,” Journal of Investment Compliance, Vol. 8, No. 3, 2007 (co-author)
- “Ask Not For Whom the Bell Tolls, It May Toll For You Next: Intensified Anti-Money Laundering Enforcement Transforms the Regulatory Landscape,” Journal of Investment Compliance, Vol. 6, No.1, Fall 2005
- “AML Programs for Financial Institutions Under Section 352 of the USA Patriot Act,” Banking & Financial Services Policy Report, Vol. 21, No. 7, July 2002
- “Anti-Money Laundering Provisions of the USA PATRIOT Act of 2001,” CCH, April 2002
- “Are Self Regulatory Organizations State Actors? Two Recent Cases Take Contrasting Perspectives,” The Journal of Investment Compliance, Vol. 2, No. 1, Summer 2001
- “2001: A Money Laundering Space Odyssey,” Securities Industry Association Compliance and Legal Seminar on SIA Website, March 2001
- “Did Bankers Trust Alter The Rules?,” New York Law Journal, Corporate Counsel, at S4, Nov. 20, 2000
- “How Safe Is The Bank Secrecy Act Safe Harbor?,” Journal of Investment Compliance, Vol. 1, No. 2, Fall 2000
- “International Ramifications of U.S. Anti-Money Laundering Policy: Whose Law is the United States Enforcing?,” Journal of International Banking Law, Vol. 15, Issue 4/5, April/May 2000
- “Back to the Future: How Recent Events Have Revived the Call for More Stringent Anti-Money Laundering Regulation,” Banking Policy Report, Vol. 19, No. 6, March 20, 2000
- “Money Laundering In The Millennium: A Broker-Dealer’s Guide To KYC, SAR & OFAC,” Securities Industry Association Compliance and Legal Division Annual Seminar on SIA Website, March 2000
- “Money Laundering and Suspicious Activity Reporting: Now What’s a Broker-Dealer To Do?,” Money Laundering Alert, April-July 1999 (published in four parts)
- “Never a Dull Moment: Hot Topics in AML and Financial Crimes,” SIFMA Anti-Money Laundering & Financial Crimes Conference, May 2023
- Fordham Law Women's Fifth Annual Symposium, March 2023
- “Industry Hot Topics,” SIFMA Anti-Money Laundering & Financial Crimes Conference, May 2022
- FIA Law & Compliance Division Conference, April 2021
- “Financial Crimes Case Studies: You Make the Call!,”SIFMA Anti-Money Laundering & Financial Crimes Conference, Feb. 2021
- “Confusion Worse Confounded: AML in the Capital Markets,” SIFMA Anti-Money Laundering & Financial Crimes Conference, New York, February 2019
- “Hot Topics: AML, Cybersecurity, Privacy, GDPR,” FIA Law & Compliance Division 40th Annual Law & Compliance Division Conference, Washington DC, May 2018
- “Shells and Pillars: Are You Ready?,” SIFMA Anti-Money Laundering & Financial Crimes Conference, New York, February 2018
- “DFS, State, and OFAC Officials Weigh-In on Regulatory Hot Buttons Governing the Insurance and Reinsurance Industries,” 8th Annual Forum on AML & OFAC Compliance for the Insurance Industry, January 2018
- “Developments in AML – What’s New?,” FIA Law & Compliance Division 39th Annual Law & Compliance Conference on the Regulation of Futures, Derivatives and OTC Products, May 2017
- “Crisis Management and Reactions to Breaking Events,” SIFMA 17th Annual Anti-Money Laundering & Financial Crimes Conference, February 2017
- “Regulatory and Enforcement Roundtable: Perspectives from Federal and State Agencies that Govern the Insurance and Reinsurance Industries,” ACI 7th Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2017
- “What to Do When You Suspect a Violation? Tips for Internal Investigations and Determining the Value of a Voluntary Self-Disclosure,” ACI 7th Annual New York Forum on Economic Sanctions, December 2016
- “A Financial Institution Under Criminal Investigation – Strategic Issues,” Deloitte Tenth Annual AML Conference, October 2016
- “Sanctioning Compliance Officers: External and Internal Sanctions on Compliance Officers,” NYU Law Compliance: New Risks, Challenges, and Approaches Conference, October 2016
- “Customer Due Diligence in a Global AML Environment,” SIFMA 16th Annual Anti-Money Laundering & Financial Crimes Conference, April 2016
- Co-Moderator, “Regulatory and Enforcement Roundtable: Perspectives from OFAC, the Department of State, the DOJ, and Other Federal and State Agencies That Govern the Insurance and Reinsurance Industries,” ACI 6th Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2016
- “Meeting Government’s Expectations: How Much Is Enough Due Diligence to Protect Your Organization?,” ACI 6th Annual Economic Sanctions Bootcamp, December 2015
- “AML Compliance: Hot Topics,” SIFMA Compliance & Legal Society Annual Seminar, March 2015
- “Compliance Officers and Personal Liability: Are You At Risk?,” ACAMS Webinar, March 2015
- “Lessons Learned from Enforcement,” SIFMA 15th Annual Anti-Money Laundering & Financial Crimes Conference, February 2015
- Co-Moderator, “Regulatory and Enforcement Roundtable: Perspectives from the Department of State, the Office of the New York State Attorney General, the Secret Service, and Other Federal and State Agencies That Govern the Insurance and Reinsurance Industries,” ACI 5th Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2015
- “Know Your Product: Money Laundering Risks in New and Complex Products,” ABA Money Laundering Enforcement Conference, November 2014
- “Current Regulatory and International Issues,” FIA Law & Compliance Regulatory Roundup: A Mid-Year Review for Chicago Members, September 2014
- “AML Compliance: Hot Topics,” SIFMA Compliance and Legal Society Annual Seminar, April 2014
- Moderator, “AML and Beyond: The Intersection of AML, Anti-Corruption and Sanctions,” SIFMA 14th Annual Anti-Money Laundering and Financial Crimes Conference, January 2014
- Co-Moderator, “Regulatory and Enforcement Roundtable: Perspectives from the Department of State, the DOJ, the U.S. Attorney’s Office, the Office of the New York State Attorney General, and Other Federal and State Agencies That Govern the Insurance Industry,” ACI 4th Annual Forum on AML & OFAC Compliance for the Insurance Industry, January 2014
- Co-Chair, ACI 4th Economic Sanctions Boot Camp, December 2013
- “AML Compliance — Hot Topics,” SIFMA Compliance and Legal Society Annual Seminar, March 2013
- Moderator, “Significant Sanctions Enforcement Actions and Other Financial Crime Developments,” SIFMA 13th Annual Anti-Money Laundering & Financial Crimes Conference, February 2013
- “Beneficial Ownership: Will A Risk-Based Approach Survive?” and “Broker Dealer & Wealth Management,” FIBA 13th Annual Anti-Money Laundering Compliance Conference, February 2013
- Moderator, “Conducting Effective Internal Investigations into Potential Money Laundering, Fraud, Sanctions Violations, or FCPA Violations,” ACI 3rd Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2013
- “The Aftermath of the $619 Million ING Case, and What It Says About Sanctions Penalty Calculations: Mitigating and Aggravating Factors for Financial Institutions, Non-Regulated Entities and Individuals,” ACI OFAC Boot Camp, December 2012
- “Regulatory Investigations,” PLI Bet the Company Litigation, September 2012
- “Enforcement Against Regulated Financial Institutions,” ACI 5th Advanced Forum on OFAC Enforcement and Compliance, April 2012
- “Securities Focus: Reverse Mergers, Penny Stock and Micro-Cap Securities Fraud — What are the AML Risks and Regulatory Expectations?,” ACAMS 17th Annual International Anti-Money Laundering Conference, March 2012
- “AML Compliance — Hot Topics,” SIFMA 2012 Compliance and Legal Society Annual Seminar, March 2012
- “Ten Years After 9/11: A Retrospective On How We Got Here” and “‘Who's On First?’ – Managing the Allocation of AML Responsibilities in a New Regulatory Environment,” SIFMA 12th Annual Anti-Money Laundering and Financial Crimes Conference, February 2012
- “Conducting Internal Investigations into Potential Money Laundering, Sanctions Violations, or FCPA Violations,” ACI 2nd Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2012
- “Assessing the Price of Sanctions Violations by U.S. and Non-U.S. Entities, and Individuals: The Agencies’ Approach to Global Investigations, Enforcement and Penalty Calculations,” ACI OFAC Boot Camp, December 2011
- “Gifts, Entertainment & Hospitality in High Risk Markets — A Practical Guide on What You Can and Can’t Do,” ACI 26th National Conference on the Foreign Corrupt Practices Act, November 2011
- “AML Monitoring,” SEC Roundtable on Microcap Securities, October 2011
- “Focus on Securities: Creating Optimal Customer Surveillance Programs” and “Combating Consistent Anti-Money Laundering Challenges: Topical Discussions With Subject Matter Experts,” ACAMS 10th Annual International Anti-Money Laundering Conference, September 2011
- “AML Compliance: Hot Topics,” SIFMA Compliance & Legal Society Annual Seminar, March 2011
- “Regulatory and Enforcement Roundtable,” ACI AML and OFAC, January 2011
- “AML, FCPA and OFAC: The Intersection of Three Key Risk Areas,” Schulte 20th Annual Private Investment Funds Seminar, January 2011
- “Fundamentals of FCPA Compliance: The Foreign Corrupt Practices Act Demystified,” ACI 24th Global Conference on the Foreign Corrupt Practices Act, November 2010
- “Practical Approach to Combating Consistent Anti-Money Laundering Challenges,” ACAMS 9th Annual International Anti-Money Laundering Conference, September 2010
- “AML Compliance — Current Issues,” SIFMA CL 2010 Annual Seminar, May 2010
- Moderator, “Regulator Panel — Keeping Current With Regulatory Developments to Ensure Your Institution Remains Compliant,” SIFMA 10th Annual Anti-Money Laundering Conference, March 2010
- “FCPA,” Deloitte Third Annual AML Compliance Conference, November 2009
- “Enforcement Actions — Monitoring,” ACAMS/Morgan Stanley, October 2009
- Moderator, “Regulators Insights: Avoid Penalties and Optimize Your Firm's Defense by Complying With the Latest AML and Fraud Regulations” and “Managing Compliance Requirements for Clearing and Introducing Firms in an Era of Increased Scrutiny and Reduced Resources,” 19th Annual AMLAC & Fraud Forum, October 2009
- “Money Laundering and Asset Forfeiture,” ABA’s 23rd Annual National Institute on White Collar Crime, March 2009
- SIFMA Annual Anti-Money Laundering Conference, 2001–10
- “Q&A Session: ‘Ask the Regulators’,” 2nd Annual Anti-Money Laundering & Counter-Terrorist Financing Forum, November 2007
- SIFMA Law & Compliance Division Annual Seminar, 1987–2010
- SIFMA Compliance & Legal Division Mid-Year Compliance Conference, 2004–06
- Co-chair, Institutional Investor’s Anti-Money Laundering and Counter-Terrorist Financing Forum, 2005-06
- “AML Guidance for Investment Advisors,” Investment Management Compliance Summit, September 2006
- FIA Law and Compliance Seminar, 2002–06
- Institute for International Research on Bank Secrecy Act and Anti-Money Laundering, 1996-2005 (Co-chair of program 1999–05)
- Co-chair, ICM Conference on Money Laundering, 1999–2002
- Member, Board of Directors of National Organization of Italian American Women, 2009–Present;
- Chair, 2012–2014
- Chair Elect, 2012
- Vice Chair, 2009–2011
- Former Member, Editorial Board of Complinet
- Member, Board of Trustees of Federal Bar Council Foundation, 1997–2003; 2005–2008; 2012–2019
- Member, Fordham Law Alumni Association, Board of Directors, 1997–Present
- Member, New York City Bar Association, Federal Courts Committee, 1993–1994
- Division Co-director, ABA Litigation Committee, 1991–1992
- Chair/Co-chair, ABA Securities Litigation Committee, 1989–1991
- Chair, Broker/Dealer Sub-Committee of Litigation Committee, 1987–1989
- Member, ABA White Collar Crime Committee, 1993–Present
- Secretary, New York Women's Bar Association, 1976–1977
- Founder, Fordham Law Women, 1972
- Professional Activities
- Securities Industry and Futures Industry Representative, U.S. Treasury Department Bank Secrecy Act Advisory Group, 1995–2008
- Member, SIFMA Anti-Money Laundering and Financial Crimes Committee, 2014–Present; Counsel, 2000–2014
- Member of U.S. Delegation to FATF, October 2002
- Chair, Ad Hoc Securities Industry Group on Bank Secrecy Act and Anti-Money Laundering, 1995–2000
- U.S. Securities Industry Representative, Financial Action Task Force, 1998
- The Best Lawyers in America
- Ethisphere: Attorneys Who Matter
- Expert Guide to the World’s Leading White Collar Crime Lawyers
- Expert Guide to the World’s Leading Women in Business Law (White Collar Crime)
- Who's Who Legal: Business Crime Defence
- The Legal 500 US
- New York Super Lawyers
- Top Women Attorneys in the New York Metro Area
- 2014 Recipient, SIFMA Award in recognition of extraordinary contributions to the Anti-Money Laundering and Financial Crimes Committee
- 2011 Recipient, Highly Commended Award, Emerald Literati Network
- 2009 Recipient, NOW-NYC Women of Power & Influence Award
- 2008 Recipient, Burton Award for Distinguished Legal Writing for article titled "The Foreign Corrupt Practices Act: Recent Cases and Enforcement Trends"
- 2006 Recipient, Outstanding Paper Award, Emerald Literati Network
- 1998 Recipient, Director's Medal for Exceptional Service, Financial Crimes Enforcement network of the United States Treasury Department
- 1988 Recipient, YWCA Women of Achievement Award
- Merrill Lynch Pierce Fenner and Smith Inc., 1983-1997
- First Vice President and Assistant General Counsel
- U.S. Attorney’s Office, Southern District of New York, 1977-1983
- Assistant U.S. Attorney
- Fordham University School of Law, 1982-1984, 2003
- Adjunct Professor of Law
- Martin, Obermaier & Morvillo, 1974–1976
- Associate
- Involved in numerous representations of large banks and broker-dealers in connection with possible AML/BSA violations before the SEC, FINRA, the bank regulators and FinCEN.
- Conducting internal investigation into possible money laundering and foreign tax fraud by foreign institutional client of U.S. commercial bank.
- Representation of global financial institution in international money laundering investigation.
- Representation of major securities firm in parallel N.Y. District Attorney’s Office, SEC and federal grand jury investigations into possible Martin Act violations, securities fraud, tax evasion and money laundering.
- Independent consultant retained to review the NYSE’s rules, practices and procedures applicable to floor members.
- Representation of foreign banks before OCC in connection with negotiation of settlement agreement and examination by SEC.
- Advise large private equity funds and private investment funds in connection with establishing of AML/sanctions programs.
Books/Treatises
- “Civil and Criminal Enforcement,” Insider Trading Law and Compliance Answer Book (Practising Law Institute), 2011–2020
- Private Equity Funds: Formation and Operation (Practising Law Institute) (contributor)
- Hedge Funds: Formation, Operation and Regulation (ALM Law Journal Press) (contributor)
- “Representation Prior to Indictment,” Defending Federal Criminal Cases: Attacking the Government's Proof (Law Journal Press), 2009, 2015, 2021 (co-author)
- “Anti-Money Laundering Regulations Applicable to Broker-Dealers,” Broker Dealer Regulation (Practising Law Institute), September 2014
- “Anti-Money Laundering,” Practitioner’s Guide for Broker-Dealers (Complinet), Nov. 11, 2010 (co-author)
- “Clearing Broker Liability and Responsibilities,” Broker Dealer Regulation (Practising Law Institute),May 2010 (co-author)
- “Specific Corporate Compliance Challenges by Practice Area: Anti-Money Laundering,” The Corporate Compliance Practice Guide: The Next Generation (Matthew Bender/LexisNexis), 2009 (co-author)
- “Anti-money Laundering Regulation of Broker-Dealers,” Broker Dealer Regulation, Chapter 18, June 2009 (co-author)
- “Mutual Fund Compliance and the Anti-Money Laundering Regulatory Regime, Part I and II,” The Review of Securities & Commodities Regulation, September 2005 and September 2007
- “The Anti-Money Laundering Regime for the Futures Industry,” The Review of Securities & Commodities Regulation, March 2007
- “Suitability in Cyberspace,” Securities & Commodities Regulation, Vol. 34, No. 11, June 13, 2001
- “The Foreign Corrupt Practices Act and Money Laundering,” Conducting Due Diligence (Practising Law Institute), May 1999
- “Money Laundering and Suspicious Activity Reporting,” Securities and Commodities Regulation, Vol. 31, No. 15, Sept. 9, 1998
Articles
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“FinCEN Issues Final Rule Requiring AML Reporting for Real Estate Sector,” Schulte Alert, Nov. 5, 2024
- “The Corporate Transparency Act: Filing Deadline Fast Approaching,” Schulte Alert, Oct. 22, 2024
- “FinCEN Issues Final AML/CFT Program Rule for Certain Investment Advisers,” Schulte Alert, Sept. 30, 2024
- “FinCEN Issues Proposed Rule to Strengthen and Modernize AML/CFT Programs for Financial Institutions,” Schulte Alert, Aug. 16, 2024
- “Sanctions Update: Statutory Amendments and an Interim Final Rule Create Significant Implications for OFAC Sanctions Compliance,” Schulte Alert, June 11, 2024
- “FinCEN Issues Proposed Rule Requiring Customer Identification Programs for Investment Advisers,” Schulte Alert, June 11, 2024
- “FinCEN Issues Proposed Rule to Implement AML Reporting Requirements for Real Estate Sector,” Schulte Alert, May 3, 2024
- “Sanctions Update: OFAC Re-Emphasizes Applicability of Sanctions to Non-US Persons,” Schulte Alert, April 4, 2024
- “FinCEN Once Again Proposes Anti-Money Laundering Program Requirements for Investment Advisers,” Schulte Alert, March 18, 2024
- “Corporate Transparency Act Update: Federal District Court Rules the Act Unconstitutional,” Schulte Alert, March 5, 2024
- “Corporate Transparency Act Update: Beneficial Ownership Reporting Rule Now Effective and FinCEN Is Accepting Reports,” Schulte Alert, Jan. 4, 2024
- “The Corporate Transparency Act: Final Rule on Access to Beneficial Ownership Information,” Schulte Alert, Jan. 2, 2024
- “Anti-Money Laundering Update: Treasury to Re-Propose Long Anticipated AML Program Rules Aimed at Hedge Funds, PE Funds and Certain Investment Advisers,” Schulte Alert, Dec. 22, 2023
- “The Corporate Transparency Act: FinCEN Extends Filing Deadline From 30 to 90 Days For Reporting Companies Created or Registered in 2024,” Schulte Alert, Dec. 1, 2023
- “CFPB Proposes Rule Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications,” Schulte Alert, Nov. 16, 2023
- “California Passes Portions of the Model Money Transmission Modernization Act,” Schulte Alert, Oct. 12, 2023
- “Key Takeaways From Agencies’ Tri-Seal Compliance Note,” Law360, Aug. 25, 2023
- “SEC Exam Staff Issues Alert Highlighting Deficiencies in Broker-Dealers’ AML Programs,” Schulte Alert, Aug. 25, 2023
- “Sanctions Update: OFAC Encourages Voluntary Self-Disclosure for Sanctions Violations,” Schulte Alert, Aug. 2, 2023
- “What To Note In FinCEN, DOJ Action Against Crypto Exchange,” Law360, April 18, 2023
- “Alumnae Founders of Groups for Women and Black Students Speak at Fordham Law Women Symposium,” Fordham Law News, April 4, 2023 (quoted)
- Securities Enforcement Quarterly, Schulte Publication, February 2023
- “FinCEN Issues Proposed Access Rule and Proposed Forms to Further Implement the CTA,” Schulte Alert, Feb. 7, 2023
- “FinCEN Identifies Bitzlato as a 'Primary Money Laundering Concern' in First-Time Use of Section 9714(a) and DOJ Charges Its Founder with Owning an Unlicensed Money Transmitting Business,” Schulte Alert, Feb. 3, 2023
- “NYDFS Releases Guidance for BitLicensees and Limited Purpose Trust Companies on Asset Custody in the Wake of Cryptocurrency Insolvencies,” Schulte Alert, Jan. 31, 2023
- “NYDFS Announces $100 Million Settlement with Coinbase for AntiMoney Laundering Compliance Deficiencies,” Schulte Alert, Jan. 23, 2023
- “AML Recent Developments: What Practitioners Need to Know,” The Review of Securities & Commodities Regulation, Nov. 9, 2022
- “FinCEN Issues Final Rule Requiring Reporting of Beneficial Ownership Information,” Schulte Alert, Oct. 20, 2022
- Securities Enforcement Quarterly, Schulte Publication, August 2022
- “Russian Sanctions Update: OFAC Issues Broad Restrictions on ‘New Investment’ in Russia,” Schulte Alert, June 10, 2022
- Securities Enforcement Quarterly, Schulte Publication, May 2022
- “Russian Sanctions Update: FinCEN and NYDFS Issue Guidance,” Schulte Alert, April 25, 2022
- “Sanctions Update: US Imposes Sweeping Sanctions Against Russia and Belarus,” Schulte Alert, Feb. 28, 2022
- “Sanctions Update: US Begins to Roll Out Sanctions Against Russia,” Schulte Alert, Feb. 23, 2022
- “FinCEN Commences Rulemaking Process to Implement AML Reporting Requirements for Real Estate Sector,” Schulte Alert, Feb. 11, 2022
- Securities Enforcement Quarterly January 2022, Schulte Publication, Jan. 2022
- “FinCEN Issues Notice of Proposed Rulemaking Regarding Beneficial Ownership Information Reporting Requirements Under the Corporate Transparency Act,” Schulte Alert, Jan. 14, 2021
- “US Expands Sanctions Against Belarus, Barring New Sovereign Debt Transactions,” Schulte Alert, Dec. 10, 2021
- Securities Enforcement Quarterly, Schulte Publication, October 2021; republished in the Harvard Law School Forum on Corporate Governance, November 2021
- “FATF Releases Anticipated Guidance for Virtual Assets and Virtual Asset Service Providers, Survey Results on Cross-Border Payments and Proposed Revisions to Beneficial Ownership Standard,” Schulte Alert, Nov. 30, 2021
- “Treasury Issues Reports and Guidance to Assist Industry In Addressing Threats Posed by Certain Virtual Currency Transactions and Ransomware Payments,” Schulte Alert, Oct. 28, 2021
- “FinCEN Issues First National AML/CFT Priorities and Defers Implementation of Priorities and No-Action Letter Process to Future Rulemakings,” Schulte Alert, July 12, 2021
- Securities Enforcement Quarterly, Schulte Publication, July 2021
- “Federal Banking Regulators Update Guidance on Model Risk Management Practices for AML and Sanctions Compliance,” Schulte Alert, June 10, 2021
- “White House Revamps Chinese Securities Trading Ban,” Schulte Alert, June 8, 2021
- Securities Enforcement Quarterly, Schulte Publication, April 2021
- “FinCEN Commences Rulemaking Process for Implementation of Corporate Transparency Act Requiring Disclosure of Beneficial Ownership Information,” Schulte Alert, April 26, 2021; republished in the Harvard Law School Forum on Corporate Governance, May 11, 2021
- “Broker-Dealers and Mutual Funds: Increased Regulatory Focus on Suspicious Activity Monitoring and Reporting Requirements,” Schulte Alert, April 1, 2021
- “US Sanctions on Chinese Company Securities: Further Developments,” Schulte Alert, Jan. 19, 2021
- “Passage of Anti-Money Laundering Act of 2020 Includes Comprehensive BSA/AML Reform Measures,” Schulte Alert, Jan. 7, 2021
- “OFAC Provides Guidance on Trading Ban in Chinese Companies,” Schulte Alert, Dec. 31, 2020
- “FinCEN Releases Notice of Proposed Rulemaking and FAQs Concerning Convertible Virtual Currency and Legal Tender Digital Asset Transactions,” Schulte Alert, Dec. 23, 2020
- “SEC Staff Bulletin Highlights AML Risks Associated with Low-Priced Securities Trading in Omnibus Accounts,” Schulte Alert, Dec. 14, 2020
- “Treasury Issues Advisories Related to Ransomware Attacks,” Schulte Alert, Dec. 1, 2020
- “White House Bans Trading in 31 Chinese Companies,” Schulte Alert, Nov. 13, 2020
- “AML Managers Question FinCEN’s New Effectiveness Test,” FinOps Report, Oct. 7, 2020 (quoted)
- “FinCEN and Banking Agencies Provide Clarification on PEP Screening Best Practices,” Schulte Alert, Oct. 5, 2020
- “AML Update: FinCEN Issues First-Ever Enforcement Guidelines and Federal Banking Agencies Update Enforcement Guidance,” Schulte Alert, Sept. 2, 2020; republished in The Banking Law Journal, February 2021
- “Sanctions Update: OFAC Regulations, Advisories and Enforcement Actions: November 2019 through July 2020,” Schulte Alert, August 7, 2020; republished in The Hedge Fund Journal, September 2020
- “Sanctions Update: US Sanctions Compliance During COVID-19,” Schulte Alert, April 24, 2020
- “US Government Continues to Penalize Unauthorized Disclosures of Suspicious Activity Reports,” Schulte Alert, Feb. 24, 2020
- “Mitigating OFAC Risks in Mergers and Acquisitions,” Schulte Alert, Feb. 3, 2020; republished in Thomson Reuters Westlaw Journal Bankruptcy, March 24, 2020
- “Sanctions Update: DOJ Revises Voluntary Self-Disclosure Policy for Export Control and Sanctions Violations,” Schulte Alert, Jan. 2, 2020
- “OFAC Expands Reporting Obligations and Highlights Importance of Cooperation,” Schulte Alert, Nov. 21, 2019; republished in The Hedge Fund Journal, February 2020
- “Sanctions Update: Iran, Venezuela, Ukraine, Nicaragua and Cuba,” Schulte Alert, Oct. 11, 2019 (co-author)
- “Federal Banking Regulators Issue Joint Statement on BSA/AML Compliance Program Examinations,” Schulte Alert, August 1, 2019 (co-author)
- “OFAC Update: A Framework for Compliance and Recent Settlements,” Schulte Alert, July 12, 2019 (co-author); republished in The Hedge Fund Journal, August 2019
- “FinCEN Assesses Civil Money Penalty Against P2P Currency Exchanger for BSA Violations,” Schulte Alert, April 26, 2019 (co-author)
- “Sanctions Update: Venezuela,” Schulte Alert, April 4, 2019 (co-author)
- “Sanctions Update: OFAC Sanctions Venezuela’s State-Owned Oil Company,” Schulte Alert, Feb. 8, 2019 (co-author)
- “Federal Banking Regulators Issue Joint Statement Encouraging Innovation in BSA/AML Compliance,” Schulte Alert, Dec. 5, 2018 (co-author)
- “Sanctions, Sanctions and More Sanctions!” The Hedge Fund Journal, December 2018 (co-author)
- “Sanctions Update: Iran, Venezuela and Russia,” Schulte Alert, Nov. 13, 2018 (co-author)
- “Arrest of FinCEN Employee for Unlawful Disclosure of SARs and SAR Information,” Schulte Alert, Oct. 19, 2018 (co-author)
- “FinCEN and Federal Banking Agencies Issue Statement on Pooling Resources for BSA Compliance,” Schulte Alert, Oct. 5, 2018 (co-author)
- “Sanctions Update: Iran, Global Magnitsky and Sudan,” Schulte 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,” Schulte Alert, June 4, 2018 (co-author)
- “OFAC Focuses on Oligarchs, Adds Sanctions on Russian Persons and Entities,” Schulte Alert, April 26, 2018 (co-author)
- “NYDFS Issues Guidance to Deter Fraud and Manipulation in Virtual Currency Markets,” Schulte Alert, Feb. 9, 2018 (co-author)
- “Treasury Identifies Russian Political Figures and Oligarchs,” Schulte Alert, Feb. 1, 2018 (co-author)
- “Sanctions and AML Update: North Korea and Venezuela,” Schulte Alert, Sept. 27, 2017 (co-author); republished in The Hedge Fund Journal, October 2017
- “Sanctions Update: U.S. Imposes Immediate Restrictions Relating to Venezuelan Securities,” Schulte Alert, Aug. 28, 2017 (co-author)
- “Sanctions Update: Russia, Iran, North Korea and Venezuela,” Schulte Alert, Aug. 2, 2017 (co-author); republished in The Hedge Fund Journal, August 2017
- “FinCEN Issues Assessment Against Virtual Currency Exchange — the First Enforcement Action Against a Foreign-Located Money Services Business,” Schulte Alert, July 27, 2017 (co-author); republished in PaymentsJournal, Aug. 14, 2017
- “FinCEN Renews GTOs Targeting Real Estate Transactions,” Schulte Alert, March 1, 2017 (co-author)
- “FinCEN Issues Suspicious Activity Report Guidance Concerning Cybersecurity,” Schulte Alert, Nov. 1, 2016 (co-author)
- “DOJ and OFAC Take Enforcement Action Against Canadian Payment Processor,” Schulte 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,” Schulte Alert, July 6, 2016 (co-author); republished in Westlaw Journal — Bank & Lender Liability, Sept. 19, 2016
- “US Eases Sanctions on Burma,” Schulte Alert, May 31, 2016 (co-author)
- “Highlights of FinCEN’s Long-Awaited Customer Due Diligence Final Rule,” Schulte Alert, May 11, 2016 (co-author); republished in The Hedge Fund Journal, June 2016
- “OFAC and BIS Amend Cuba Sanctions Regulations,” Schulte Alert, Feb. 1, 2016 (co-author)
- “New AML Regulatory Initiative Targets Real Estate Industry,” Schulte 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,” Schulte Alert, Jan. 20, 2016 (co-author); republished in Business Crimes Bulletin, June 2016
- “NYDFS Proposes New AML/Sanctions Programs and Annual Certification Requirements for Banks, Money Transmitters and Check Cashers,” Schulte Alert, Dec. 4, 2015 (co-author)
- “The New AML Rules: Implications for Private Fund Managers,” Schulte 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)
- “BHP Billiton Settles with SEC for $25 Million for Providing Foreign Officials with Luxury Travel to Olympics,” Schulte Alert, May 21, 2015 (co-author)
- “PayPal Settlement Highlights OFAC Risks for Money Services Businesses,” Schulte Alert, March 27, 2015 (co-author)
- “Federal and State Regulators Target Compliance Officers,” Schulte Alert, Feb. 20, 2015 (co-author)
- “Sanctions Update: Crimea,” Schulte Alert, Feb. 5, 2015 (co-author); republished in Westlaw Journal – Securities Litigation & Regulation, March 5, 2015
- “FinCEN’s Much Anticipated Proposed Rule on Customer Due Diligence Is Finally Here,” Financial Fraud Law Report, November/December 2014 (co-author)
- “Sanctions Update: Sectoral Sanctions Against Russia Escalate,” Schulte Alert, Sept. 18, 2014 (co-author); republished in Westlaw Journal – Securities Litigation & Regulation, Oct. 16, 2014
- “FinCEN’s Much-Anticipated Proposed Rule on Customer Due Diligence Is Finally Here,” Schulte Alert, Aug. 8, 2014 (co-author)
- Schulte Insider Trading Developments Newsletter, Summer 2014 (contributor)
- “Threatened Sectoral Sanctions Against Russia Become Reality,” Schulte Alert, July 30, 2014 (co-author)
- “Escalating U.S.–Russia Tensions Lead to New Sanctions, Heightened AML Risks,” Schulte Alert, April 4, 2014 (co-author)
- “Funds Face New Sanctions, AML Risks in Wake of Escalating U.S.–Russia Tensions,” Schulte Alert, April 4, 2014 (co-author)
- “FinCEN Issues Final Rules Relating to Money Services Business (MSB) Definitions,” Journal of Investment Compliance, April 2012 (co-author)
- “Recent FCPA Developments Highlight Risk of Individual Liability,” Financial Fraud Law Report, March 2012 (co-author)
- “The FCPA and AML Statutes: Prosecutors Increasingly Combining Charges, to Great Effect,” Business Crimes Bulletin, January 2012 (co-author)
- “The FCPA and AML Statutes: The Prosecutor’s Combined Weapon of Choice,” Business Crimes Bulletin, December 2011 (co-author)
- “Government Launches FCPA Inquiry into Investments by Sovereign Wealth Funds in U.S. Banks and Private Equity Firms,” Financial Fraud Law Report, July/August 2011 (co-author)
- “SEC Extends and Modifies Its No-Action Relief for BDs to Rely on RIAs for Performance of CIP” (Complinet), March 8, 2011 (co-author)
- “FinCEN and Regulators Issue Joint Guidance on Obtaining Beneficial Ownership Information, Potentially Expanding Certain Financial Institutions’ USA PATRIOT Act Obligations,” Journal of Investment Compliance, Nov. 22, 2010
- “FinCEN and SEC Sanction Broker-Dealer and Chief Compliance Officer for AML Deficiencies Relating to Foreign Sub-Accounts” (Complinet), Oct. 6, 2010
- “Bribery Act 2010,” The Hedge Fund Journal, September 2010 (co-author)
- “Practice Note: Developing an Effective AML Compliance Program for Hedge Funds” (Complinet), Feb. 12, 2008
- “The Foreign Corrupt Practices Act: Recent Cases and Enforcement Trends,” Journal of Investment Compliance, Vol. 8, No. 3, 2007 (co-author)
- “Ask Not For Whom the Bell Tolls, It May Toll For You Next: Intensified Anti-Money Laundering Enforcement Transforms the Regulatory Landscape,” Journal of Investment Compliance, Vol. 6, No.1, Fall 2005
- “AML Programs for Financial Institutions Under Section 352 of the USA Patriot Act,” Banking & Financial Services Policy Report, Vol. 21, No. 7, July 2002
- “Anti-Money Laundering Provisions of the USA PATRIOT Act of 2001,” CCH, April 2002
- “Are Self Regulatory Organizations State Actors? Two Recent Cases Take Contrasting Perspectives,” The Journal of Investment Compliance, Vol. 2, No. 1, Summer 2001
- “2001: A Money Laundering Space Odyssey,” Securities Industry Association Compliance and Legal Seminar on SIA Website, March 2001
- “Did Bankers Trust Alter The Rules?,” New York Law Journal, Corporate Counsel, at S4, Nov. 20, 2000
- “How Safe Is The Bank Secrecy Act Safe Harbor?,” Journal of Investment Compliance, Vol. 1, No. 2, Fall 2000
- “International Ramifications of U.S. Anti-Money Laundering Policy: Whose Law is the United States Enforcing?,” Journal of International Banking Law, Vol. 15, Issue 4/5, April/May 2000
- “Back to the Future: How Recent Events Have Revived the Call for More Stringent Anti-Money Laundering Regulation,” Banking Policy Report, Vol. 19, No. 6, March 20, 2000
- “Money Laundering In The Millennium: A Broker-Dealer’s Guide To KYC, SAR & OFAC,” Securities Industry Association Compliance and Legal Division Annual Seminar on SIA Website, March 2000
- “Money Laundering and Suspicious Activity Reporting: Now What’s a Broker-Dealer To Do?,” Money Laundering Alert, April-July 1999 (published in four parts)
- “Never a Dull Moment: Hot Topics in AML and Financial Crimes,” SIFMA Anti-Money Laundering & Financial Crimes Conference, May 2023
- Fordham Law Women's Fifth Annual Symposium, March 2023
- “Industry Hot Topics,” SIFMA Anti-Money Laundering & Financial Crimes Conference, May 2022
- FIA Law & Compliance Division Conference, April 2021
- “Financial Crimes Case Studies: You Make the Call!,”SIFMA Anti-Money Laundering & Financial Crimes Conference, Feb. 2021
- “Confusion Worse Confounded: AML in the Capital Markets,” SIFMA Anti-Money Laundering & Financial Crimes Conference, New York, February 2019
- “Hot Topics: AML, Cybersecurity, Privacy, GDPR,” FIA Law & Compliance Division 40th Annual Law & Compliance Division Conference, Washington DC, May 2018
- “Shells and Pillars: Are You Ready?,” SIFMA Anti-Money Laundering & Financial Crimes Conference, New York, February 2018
- “DFS, State, and OFAC Officials Weigh-In on Regulatory Hot Buttons Governing the Insurance and Reinsurance Industries,” 8th Annual Forum on AML & OFAC Compliance for the Insurance Industry, January 2018
- “Developments in AML – What’s New?,” FIA Law & Compliance Division 39th Annual Law & Compliance Conference on the Regulation of Futures, Derivatives and OTC Products, May 2017
- “Crisis Management and Reactions to Breaking Events,” SIFMA 17th Annual Anti-Money Laundering & Financial Crimes Conference, February 2017
- “Regulatory and Enforcement Roundtable: Perspectives from Federal and State Agencies that Govern the Insurance and Reinsurance Industries,” ACI 7th Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2017
- “What to Do When You Suspect a Violation? Tips for Internal Investigations and Determining the Value of a Voluntary Self-Disclosure,” ACI 7th Annual New York Forum on Economic Sanctions, December 2016
- “A Financial Institution Under Criminal Investigation – Strategic Issues,” Deloitte Tenth Annual AML Conference, October 2016
- “Sanctioning Compliance Officers: External and Internal Sanctions on Compliance Officers,” NYU Law Compliance: New Risks, Challenges, and Approaches Conference, October 2016
- “Customer Due Diligence in a Global AML Environment,” SIFMA 16th Annual Anti-Money Laundering & Financial Crimes Conference, April 2016
- Co-Moderator, “Regulatory and Enforcement Roundtable: Perspectives from OFAC, the Department of State, the DOJ, and Other Federal and State Agencies That Govern the Insurance and Reinsurance Industries,” ACI 6th Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2016
- “Meeting Government’s Expectations: How Much Is Enough Due Diligence to Protect Your Organization?,” ACI 6th Annual Economic Sanctions Bootcamp, December 2015
- “AML Compliance: Hot Topics,” SIFMA Compliance & Legal Society Annual Seminar, March 2015
- “Compliance Officers and Personal Liability: Are You At Risk?,” ACAMS Webinar, March 2015
- “Lessons Learned from Enforcement,” SIFMA 15th Annual Anti-Money Laundering & Financial Crimes Conference, February 2015
- Co-Moderator, “Regulatory and Enforcement Roundtable: Perspectives from the Department of State, the Office of the New York State Attorney General, the Secret Service, and Other Federal and State Agencies That Govern the Insurance and Reinsurance Industries,” ACI 5th Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2015
- “Know Your Product: Money Laundering Risks in New and Complex Products,” ABA Money Laundering Enforcement Conference, November 2014
- “Current Regulatory and International Issues,” FIA Law & Compliance Regulatory Roundup: A Mid-Year Review for Chicago Members, September 2014
- “AML Compliance: Hot Topics,” SIFMA Compliance and Legal Society Annual Seminar, April 2014
- Moderator, “AML and Beyond: The Intersection of AML, Anti-Corruption and Sanctions,” SIFMA 14th Annual Anti-Money Laundering and Financial Crimes Conference, January 2014
- Co-Moderator, “Regulatory and Enforcement Roundtable: Perspectives from the Department of State, the DOJ, the U.S. Attorney’s Office, the Office of the New York State Attorney General, and Other Federal and State Agencies That Govern the Insurance Industry,” ACI 4th Annual Forum on AML & OFAC Compliance for the Insurance Industry, January 2014
- Co-Chair, ACI 4th Economic Sanctions Boot Camp, December 2013
- “AML Compliance — Hot Topics,” SIFMA Compliance and Legal Society Annual Seminar, March 2013
- Moderator, “Significant Sanctions Enforcement Actions and Other Financial Crime Developments,” SIFMA 13th Annual Anti-Money Laundering & Financial Crimes Conference, February 2013
- “Beneficial Ownership: Will A Risk-Based Approach Survive?” and “Broker Dealer & Wealth Management,” FIBA 13th Annual Anti-Money Laundering Compliance Conference, February 2013
- Moderator, “Conducting Effective Internal Investigations into Potential Money Laundering, Fraud, Sanctions Violations, or FCPA Violations,” ACI 3rd Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2013
- “The Aftermath of the $619 Million ING Case, and What It Says About Sanctions Penalty Calculations: Mitigating and Aggravating Factors for Financial Institutions, Non-Regulated Entities and Individuals,” ACI OFAC Boot Camp, December 2012
- “Regulatory Investigations,” PLI Bet the Company Litigation, September 2012
- “Enforcement Against Regulated Financial Institutions,” ACI 5th Advanced Forum on OFAC Enforcement and Compliance, April 2012
- “Securities Focus: Reverse Mergers, Penny Stock and Micro-Cap Securities Fraud — What are the AML Risks and Regulatory Expectations?,” ACAMS 17th Annual International Anti-Money Laundering Conference, March 2012
- “AML Compliance — Hot Topics,” SIFMA 2012 Compliance and Legal Society Annual Seminar, March 2012
- “Ten Years After 9/11: A Retrospective On How We Got Here” and “‘Who's On First?’ – Managing the Allocation of AML Responsibilities in a New Regulatory Environment,” SIFMA 12th Annual Anti-Money Laundering and Financial Crimes Conference, February 2012
- “Conducting Internal Investigations into Potential Money Laundering, Sanctions Violations, or FCPA Violations,” ACI 2nd Annual Forum on AML and OFAC Compliance for the Insurance Industry, January 2012
- “Assessing the Price of Sanctions Violations by U.S. and Non-U.S. Entities, and Individuals: The Agencies’ Approach to Global Investigations, Enforcement and Penalty Calculations,” ACI OFAC Boot Camp, December 2011
- “Gifts, Entertainment & Hospitality in High Risk Markets — A Practical Guide on What You Can and Can’t Do,” ACI 26th National Conference on the Foreign Corrupt Practices Act, November 2011
- “AML Monitoring,” SEC Roundtable on Microcap Securities, October 2011
- “Focus on Securities: Creating Optimal Customer Surveillance Programs” and “Combating Consistent Anti-Money Laundering Challenges: Topical Discussions With Subject Matter Experts,” ACAMS 10th Annual International Anti-Money Laundering Conference, September 2011
- “AML Compliance: Hot Topics,” SIFMA Compliance & Legal Society Annual Seminar, March 2011
- “Regulatory and Enforcement Roundtable,” ACI AML and OFAC, January 2011
- “AML, FCPA and OFAC: The Intersection of Three Key Risk Areas,” Schulte 20th Annual Private Investment Funds Seminar, January 2011
- “Fundamentals of FCPA Compliance: The Foreign Corrupt Practices Act Demystified,” ACI 24th Global Conference on the Foreign Corrupt Practices Act, November 2010
- “Practical Approach to Combating Consistent Anti-Money Laundering Challenges,” ACAMS 9th Annual International Anti-Money Laundering Conference, September 2010
- “AML Compliance — Current Issues,” SIFMA CL 2010 Annual Seminar, May 2010
- Moderator, “Regulator Panel — Keeping Current With Regulatory Developments to Ensure Your Institution Remains Compliant,” SIFMA 10th Annual Anti-Money Laundering Conference, March 2010
- “FCPA,” Deloitte Third Annual AML Compliance Conference, November 2009
- “Enforcement Actions — Monitoring,” ACAMS/Morgan Stanley, October 2009
- Moderator, “Regulators Insights: Avoid Penalties and Optimize Your Firm's Defense by Complying With the Latest AML and Fraud Regulations” and “Managing Compliance Requirements for Clearing and Introducing Firms in an Era of Increased Scrutiny and Reduced Resources,” 19th Annual AMLAC & Fraud Forum, October 2009
- “Money Laundering and Asset Forfeiture,” ABA’s 23rd Annual National Institute on White Collar Crime, March 2009
- SIFMA Annual Anti-Money Laundering Conference, 2001–10
- “Q&A Session: ‘Ask the Regulators’,” 2nd Annual Anti-Money Laundering & Counter-Terrorist Financing Forum, November 2007
- SIFMA Law & Compliance Division Annual Seminar, 1987–2010
- SIFMA Compliance & Legal Division Mid-Year Compliance Conference, 2004–06
- Co-chair, Institutional Investor’s Anti-Money Laundering and Counter-Terrorist Financing Forum, 2005-06
- “AML Guidance for Investment Advisors,” Investment Management Compliance Summit, September 2006
- FIA Law and Compliance Seminar, 2002–06
- Institute for International Research on Bank Secrecy Act and Anti-Money Laundering, 1996-2005 (Co-chair of program 1999–05)
- Co-chair, ICM Conference on Money Laundering, 1999–2002
- Member, Board of Directors of National Organization of Italian American Women, 2009–Present;
- Chair, 2012–2014
- Chair Elect, 2012
- Vice Chair, 2009–2011
- Former Member, Editorial Board of Complinet
- Member, Board of Trustees of Federal Bar Council Foundation, 1997–2003; 2005–2008; 2012–2019
- Member, Fordham Law Alumni Association, Board of Directors, 1997–Present
- Member, New York City Bar Association, Federal Courts Committee, 1993–1994
- Division Co-director, ABA Litigation Committee, 1991–1992
- Chair/Co-chair, ABA Securities Litigation Committee, 1989–1991
- Chair, Broker/Dealer Sub-Committee of Litigation Committee, 1987–1989
- Member, ABA White Collar Crime Committee, 1993–Present
- Secretary, New York Women's Bar Association, 1976–1977
- Founder, Fordham Law Women, 1972
- Professional Activities
- Securities Industry and Futures Industry Representative, U.S. Treasury Department Bank Secrecy Act Advisory Group, 1995–2008
- Member, SIFMA Anti-Money Laundering and Financial Crimes Committee, 2014–Present; Counsel, 2000–2014
- Member of U.S. Delegation to FATF, October 2002
- Chair, Ad Hoc Securities Industry Group on Bank Secrecy Act and Anti-Money Laundering, 1995–2000
- U.S. Securities Industry Representative, Financial Action Task Force, 1998
- The Best Lawyers in America
- Ethisphere: Attorneys Who Matter
- Expert Guide to the World’s Leading White Collar Crime Lawyers
- Expert Guide to the World’s Leading Women in Business Law (White Collar Crime)
- Who's Who Legal: Business Crime Defence
- The Legal 500 US
- New York Super Lawyers
- Top Women Attorneys in the New York Metro Area
- 2014 Recipient, SIFMA Award in recognition of extraordinary contributions to the Anti-Money Laundering and Financial Crimes Committee
- 2011 Recipient, Highly Commended Award, Emerald Literati Network
- 2009 Recipient, NOW-NYC Women of Power & Influence Award
- 2008 Recipient, Burton Award for Distinguished Legal Writing for article titled "The Foreign Corrupt Practices Act: Recent Cases and Enforcement Trends"
- 2006 Recipient, Outstanding Paper Award, Emerald Literati Network
- 1998 Recipient, Director's Medal for Exceptional Service, Financial Crimes Enforcement network of the United States Treasury Department
- 1988 Recipient, YWCA Women of Achievement Award
- Merrill Lynch Pierce Fenner and Smith Inc., 1983-1997
- First Vice President and Assistant General Counsel
- U.S. Attorney’s Office, Southern District of New York, 1977-1983
- Assistant U.S. Attorney
- Fordham University School of Law, 1982-1984, 2003
- Adjunct Professor of Law
- Martin, Obermaier & Morvillo, 1974–1976
- Associate
