HANDS-ON EXPERIENCE

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COMPLIANCE PRACTICE

Our compliance attorneys have hands-on experience in regulatory, compliance and ethical issues related to various types of financial institutions, including regulatory compliance work and advisory matters on behalf of banks, bank holding companies, mortgage lenders, insurance-related entities, broker-dealer and asset management firms, mutual funds and other financial services.

For clients with a focus on investment advice and asset management, our Compliance group includes a former chief compliance officer to an investment adviser firm registered with the SEC, the federal regulatory agency responsible for the licensing and supervision of federally-registered investment advisers, and holding advanced certifications such as Investment Adviser Certified Compliance Professional® (IACCP®), and prior FINRA Series 7 license.

Our team also drafts policies, procedures and disclosure documents, working with the clients based on their internal risk appetites and sensitivities, in order to deliver relevant legal advice and warn of the legal risks involved in proposed business practices.

Unlike other local law firms, due to our career experience in banking & financial services regulatory compliance, our Firm is well-suited to provide subject-matter compliance solutions related to clients’ core businesses, as well as cost-effective resolution of compliance violations. Our team includes lawyers with prior in-house legal and compliance experience for multinational and foreign banking organization groups.

SOME OF OUR COMPLIANCE SPECIALTY AREAS AND SERVICES INCLUDE:

  • Advising on implementation of initiatives in compliance with laws and regulations.
  • Drafting of policies & procedures tailored to the client’s business, products and services, including on topics of privacy, anti-money laundering (AML / KYC), economic sanctions (OFAC), data protection, information security, privacy, e-banking, vendor management, consumer protection, consumer finance, and unfair and deceptive acts and practices, among others, and advice as to internal controls.
  • Drafting disclosure documents under CFPB’s Regulation E, Regulation Z, Regulation DD and other consumer protection regulations.
  • Corporate governance policies, codes of conduct and ethics.
  • Banking, SEC and CFTC compliance under complex regulatory frameworks such as portfolio management and trading, use of derivatives, and other matters specific to the broker-dealer, asset management and investment funds industry.
  • Review and/or drafting of third-party vendor or service provider relationship agreements.
  • Regulatory compliance issues of startups and emerging companies, including fintechs and challenger banks.

Representative Experience

  • Development of compliance program and code of ethics for investment advisers as required by SEC regulation.
  • Development and/or review of multiple compliance programs, such as BSA / AML and OFAC Sanctions Monitoring Compliance Programs, for international financial entities with diverse business and product lines, including traditional banking and financial services, as well as correspondent banking, private banking, custody services and payment processing services.
  • Emerging regulatory issues related to fintech and regtech, including in the cryptocurrency space, financial privacy, FRB financial services (Fedwire, FedLine, FedNow), among others.
  • Served as liaison between the FDIC and the FRB and a potential de novo banking institution.
  • Advise investment management businesses on unusual issues such as asset custody rule and insider trading matters.
  • Assist financial entity in structuring an AML internal investigation and addressing resulting regulatory examination and enforcement action.

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