Anti-Money Laundering

The prevention of money laundering and other related financial crimes is a key focus for global regulators. Ropes & Gray advises leading investment advisers, fund managers, broker-dealers and other financial institutions on compliance with U.S., UK, and EU anti-money laundering laws and regulations, including the U.S. Bank Secrecy Act, the UK Proceeds of Crime Act 2002 (POCA), and the UK and EU Money Laundering Regulations.

We offer unmatched insight into market terms and practices, drawing on the size, scope and experience of our asset management and financial industry practices. These practices serve clients ranging from the industry’s largest and best-known asset managers to middle-market and emerging managers, as well as any underlying portfolio companies. Experienced and nimble, our anti-money laundering attorneys on both sides of the Atlantic know where the market is, and bring a pragmatic, efficient mindset to client matters.

Our cross-practice team helps clients:

• Develop and implement risk-based anti-money laundering and counter-terrorist financing (AML/CTF) compliance programs
• Manage compliance with FinCEN’s Anti-Money Laundering Program and Suspicious Activity Reporting Rule for Investment Advisers, as well as with differing and often inconsistent global regimes
• Assess AML/CTF risk in connection with new funds and strategies, including negotiation of sophisticated compliance structures to address cross-jurisdictional requirements
• Conduct time- and cost-efficient AML/CTF due diligence of prospective investors and investment opportunities
• Assess and comply with affirmative reporting obligations, including the UK’s rigorous reporting regime under POCA
• Prepare for regulatory exams and meet post-exam commitments
• Defend criminal investigations into money laundering and related financial crime
• Defend domestic or cross-border enforcement actions or proceedings concerning money laundering and related financial crime, and work proactively to secure negotiated outcomes wherever possible

Representative examples of recent our client work include:

• Acting as global AML/CTF counsel to a major U.S. investment management firm
• Conducting a product-based, AML/CTF-focused risk assessment for a leading asset manager
• Advising hundreds of asset managers and their portfolio companies on compliance with the beneficial ownership information reporting requirements of the U.S. Corporate Transparency Act and equivalent UK requirements
• Representing a global, multi-asset alternative investment firm in connection with a FINRA examination involving its broker-dealer
• Conducting annual AML/CTF compliance program assessments for a leading mutual fund
• Advising a real estate firm in connection with the acquisition of a commercial property implicated in a federal money laundering investigation
• Negotiating a global AML/CTF compliance framework with a leading financial technology platform on behalf of an investment management client
• Advising a leading private equity firm in connection with the acquisition of an investment target embroiled in an international corruption and money laundering investigation, ultimately negotiating a complex, milestone-based payment and compliance remediation plan
• Advising multiple leading private equity and asset management firms on their UK reporting obligations regarding AML/CTF-related issues affecting existing or prospective portfolio companies—we routinely assist not only with the filing of reports in the UK, but also with informing and coordinating parallel reports in the EU and/or third countries
• Representing a global financial institution in connection with a complex cross-border investigation involving authorities in the U.S., UK and Switzerland into potential money laundering and bribery offenses—no enforcement action was ultimately taken
• Representing and advising individual employees of a global financial institution in connection with compelled interviews by the UK’s financial services regulator in the context of an investigation into the financial institution’s AML/CTF systems and controls
• Advising numerous global asset managers on their AML compliance policies and procedures to ensure compliance with multiple regulatory regimes, including in the UK, Luxembourg and the United States