Brian D. Frey

• Defended a company in the cryptocurrency industry in a joint civil and criminal investigation of BSA/AML and sanctions issues by the DOJ, the Financial Crimes Enforcement Network (FinCEN), and the Department of the Treasury’s Office of Foreign Assets Controls (OFAC).
• Conducted an internal investigation on behalf of a global automotive industry manufacturer in the automotive industry resulting in a voluntary self-disclosure to DOJ and the SEC of FCPA issues. The government ultimately declined to prosecute or take any enforcement action.
• Advised a multinational bank on a global risk assessment and revisions to its BSA/AML and sanctions policies and procedures.
• Counseled a payments company on BSA/AML and sanctions risks associated with cross-border transactions.
• Advised a mortgage industry company on the creation and implementation of new BSA/AML/sanctions programs, including drafting all the relevant policies and procedures.
• Represented a foreign purchaser of U.S. real estate in submitting a voluntary declaration to the Committee on Foreign Investment in the United States (CFIUS).
• Advised a company in the cryptocurrency industry on review and revisions to its BSA/AML and sanctions program and in responding to related reviews by financial industry regulators.
• Conducted an internal investigation and defended a manufacturing company against alleged civil and criminal violations of sanctions laws resulting in an eventual decision by DOJ and OFAC to decline to prosecute or take enforcement action against the company.
• Conducted an internal investigation and defended a multinational bank against potential violations of sanctions laws related to alleged payments to embargoed companies and Specially Designated Nationals (SDNs) involving DOJ, OFAC, the Federal Reserve (Fed), and the New York Department of Financial Services (NY DFS).
• Conducted an investigation into a U.S. bank and a broker-dealer for potential violations of the Bank Secrecy Act and related offenses in connection with the apparent laundering of more than $100 million in criminal proceeds through customer accounts.

Brian Frey is a seasoned legal expert focusing on the complex interplay of white collar crime, government investigations, and international trade law. With nearly two decades of experience, he empowers clients to navigate the intricate landscape of regulatory compliance, including developing and implementing robust compliance programs.

Brian's expertise spans a wide range of areas, including Office of Foreign Assets Control sanctions, Bureau of Industry and Security export controls, anti-money laundering, customs laws, and Foreign Corrupt Practices Act.

Drawing on his tenure as a federal prosecutor at the U.S. Department of Justice, Brian also conducts thorough internal investigations and vigorously defends his clients against civil and criminal investigation related to these subject matters.

Brian’s diverse clientele crosses virtually all industries and includes financial institutions, tech companies, manufacturers, and multinational corporations operating in various industries.  Regardless of the industry, Brian is committed to providing his clients with clear, practical guidance in even the most complex circumstances.

Brian regularly publishes on the topics above and has been quoted in numerous media outlets, including The Wall Street Journal, Bloomberg, S&P Global, the Associated Press, Slate, the Anti-Corruption Report, and the Bureau of Investigative Journalism, among others.  Brian was also recognized Law360 as a “Rising Star” in White Collar.

Bar Admissions

• Maryland
• District of Columbia

Education

• Georgetown University (J.D., 2007)
• University of Notre Dame (B.A., 2004)