Flannery | Georgalis, LLC has substantial experience addressing complex regulatory, enforcement, and internal investigative issues affecting financial institutions. Our team is special because it comprises a cross-disciplinary group of former federal prosecutors, former federal law enforcement agents, and former bank examiners and investigators who have deep knowledge, training, and experience in Anti-Money Laundering (AML), Bank Secrecy Act (BSA), internal investigations, and other financial regulatory matters. We work on a closely coordinated basis, as needed, to address AML/BSA compliance and enforcement concerns so that our clients may achieve their business goals.
We advise clients on developing and implementing compliance programs and conducting compliance audits. We also assist them in defending against regulatory enforcement actions, conducting internal investigations, responding to subpoenas and other demands, as well as successfully defending clients at trial. Our team has experience in assisting clients in successfully responding to negotiated settlements and consent orders. We help coordinate, navigate, and manage issues and challenges raised by consent orders, including interfacing with regulators to demonstrate compliance and progress on significant issues. Through our broad industry experience, we can effectively address issues related to efficiency improvement while maintaining acceptable AML risk levels.
Our team has broad training and experience in a full range of U.S. AML regulations and statutes, including the USA PATRIOT Act, the Bank Secrecy Act, the Foreign Account Tax Compliance Act (FATCA), Office of Foreign Asset Controls (OFAC) sanctions regulations, and equivalent laws of other countries in cases where multijurisdictional AML concerns arise. We regularly counsel banks and financial institutions on FATCA and other transaction and reputational due diligence investigations and develop compliance programs to mitigate the risk of noncompliance.
We provide highly experienced and knowledgeable investigative and AML personnel to assist in all types of AML projects. Our investigators and analysts are mostly former law enforcement with significant industry training in AML compliance and related investigative projects. Their experience and support include providing relief of temporary alert and inventory backlogs; review of historical activity; SAR writing; OFAC reviews; Know Your Customer (KYC) file reviews; Customer Identification Program remediation assignments; cryptocurrency investigative reviews; and other special AML projects.