Exploring Anti-Money Laundering Developments and Compliance Requirements in 2012

Mr. Sporkin has been a partner with BuckleySandler LLP since June 2012 and advises financial institutions on best practices regarding AML policies and procedures. Mr. Sporkin served for nearly 20 years in the Securities and Exchange Commission’s Division of Enforcement, spending considerable time investigating potential BSA violations and conducting surveillance using BSA data. In January 2010, Mr. Sporkin was selected to lead the SEC’s efforts to build and manage the Office of Market Intelligence, a new office established in the aftermath of the Madoff fraud to detect unlawful conduct spanning all SEC program areas. In that role, Mr. Sporkin oversaw the SEC’s BSA review group. By January of 2012, more than half of all Division of Enforcement investigations were being sourced out of OMI, certain of which arose out of SAR reviews, including those relating to insider trading, investment schemes, and market manipulations.

Laura Billings serves as Counsel with Miller & Chevalier and practices in the area of white collar criminal defense, with particular emphasis on complex financial crimes. She has broad experience in internal and congressional investigations, particularly those relating to criminal tax, economic sanctions and export controls, anti-money laundering, and the Foreign Corrupt Practices Act.Before joining the firm, Ms. Billings served for nine years as an Assistant District Attorney in the Manhattan District Attorney’s Office. Her work at that office focused on financial investigations conducted in partnership with federal and international law enforcement and regulatory entities. The cases she handled involved issues such as use of offshore bank secrecy jurisdictions to commit securities fraud, tax evasion, and money laundering; violations of the Bank Secrecy Act; illegal money remittance operations; abuses of correspondent banking relationships; and prohibited use of the U.S. financial system by foreign entities.

Prior to joining Arnold & Porter in 2006, Brian McCormally served as Director of the Enforcement and Compliance Division of the OCC, and overall has more than 20 years of service in senior enforcement and regulatory compliance positions there and at the OTS. He currently represents clients in a variety of enforcement actions or investigative proceedings brought by federal or state agencies. He has led the firm’s representation of clients in matters relating to regulatory approval of significant recapitalizations of troubled banks, the settlement of multi-billion dollar bankruptcy claims filed by troubled banks, and the successful resolution of two multi-billion dollar banks with a parent holding company in bankruptcy; enforcement actions alleging unfair or deceptive lending and marketing practices, Bank Secrecy Act and anti-money laundering non-compliance, and consumer disclosures and lending practices violations; conservatorship and receivership issues; and general safety and soundness criticisms. While in the government, Mr. McCormally had key leadership experience in BSA/AML compliance. Among other things, he developed and implemented strategies to evaluate the adequacy and effectiveness of BSA/AML compliance programs of national banks and branches of foreign banks; served as legal advisor to senior OCC officials on significant BSA/AML compliance program issues of national banks and federal branches of foreign banks; served as legal reviewing official for all recommended BSA/AML and USA PATRIOT Act violations and enforcement actions; and negotiated resolutions and/or oversaw litigation of enforcement actions designed to address BSA/AML and anti-terrorist financing compliance program deficiencies. Mr. McCormally is profiled in the 2012 edition of Chambers USA: America’s Leading Lawyers for Business as a leading practitioner in Financial Services Regulation: Banking (Enforcement & Investigations).