The Bank Secrecy Act requires many types of businesses to implement an anti-money laundering program, and all businesses are required to comply with trade and financial transaction embargoes. Every business has unique attributes and risks to consider in designing, implementing and testing its anti-money laundering and trade embargo compliance programs. McGuireWoods’ GRCI team has a proven ability to assess clients’ risks and understand their needs.
Our anti-money laundering and trade embargo compliance team includes attorneys with years of white collar crime and internal investigations experience. We have several former federal prosecutors who put their government experience to use counseling companies on federal reporting, compliance and record-keeping requirements, as well as on avoiding involuntary involvement in money laundering and illicit trading and financing.
The GRCI team provides assistance in what we have found to be the four pillars of a comprehensive anti-money laundering program. Following a self-assessment of the risk of being used for money laundering, a covered business must develop a written program that will:
- Establish policies, procedures and internal controls designed to ensure compliance with anti-money laundering regulations.
- Designate a compliance officer to coordinate and monitor the anti-money laundering program.
- Provide training for appropriate personnel.
- Implement a plan for independent review of the anti-money laundering program.
The GRCI team also counsels companies that engage in businesses that make them susceptible to the laws that impose trade and financial transaction embargoes against hostile nations, companies and individuals.
For example, certain trade and financial transaction embargoes target Cuba, Iran, Iraq, North Korea, Sudan and other hostile nations. In addition to targeted countries, a published list of Specially Designated Nationals and Blocked Persons (SDNs) includes more than 6,000 names of companies and individuals throughout the world connected to foreign narcotics traffickers, foreign terrorists and proliferators of weapons of mass destruction.