- 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.
Partner,
- Phone: 202.239.3067
- Email: brian.frey@alston.com
Brian’s comprehensive experience on both sides of white collar investigations allows him to bring an invaluable perspective to the table. Clients can depend on Brian for thorough and innovative representation in their most complex matters.