Jeff’s practice focuses on matters arising from government, regulatory, and criminal and corporate internal investigations. As a senior member of the Government Investigations & White Collar Litigation, Anti-Bribery & Anti-Corruption/ Foreign Corrupt Practices Act (FCPA), Bank Defense and Counseling and Bank Secrecy Act (BSA) / Anti-Money Laundering (AML) Counseling and Defense teams, Jeff has a particular focus on the federal BSA and related state regulations. He regularly counsels financial institutions – including national banks, money services businesses, and casinos – on their compliance obligations related to AML policies, procedures and best practices. Jeff has represented clients in investigations involving the U.S. Department of Justice (DOJ), Office of the Comptroller of the Currency (OCC), Financial Crimes Enforcement Network (FinCEN), Securities and Exchange Commission (SEC), Federal Election Commission (FEC), Consumer Financial Protection Bureau (CFPB) and other federal and state regulatory enforcement agencies.
Senior executives, directors and trustees across numerous industries including financial services, energy, healthcare, and education, have relied upon Jeff’s counsel when facing challenging and complex matters that threaten the reputation of the organization. In responding to such situations, Jeff never loses sight of business considerations and delivers practical guidance when seeking a path to resolution.
Drawing on his Spanish-language skills, Jeff has conducted FCPA, Foreign Agents Registration Act (FARA), and other types of investigations in Spain, Mexico and other Spanish-speaking jurisdictions. He also regularly represents Spanish-speaking clients in various pro bono matters related to immigration status and housing and employment matters.
Prior to joining the firm, Jeff served as a law clerk to the Honorable Donald W. Lemons, Justice of the Supreme Court of Virginia, from 2009 to 2010. Jeff also spent several years as a corporate financial analyst serving the media, entertainment and telecommunications industries at Merrill Lynch & Co. in New York.
Experience
- Represented individual client in Foreign Agents Registration Act (FARA) criminal investigation and prosecution.
- Conducted internal investigations and represented numerous private secondary schools and nonprofit entities in connection with allegations of sexual abuse.
- Led internal investigation team related to conduct at a national bank.
- Argued successful merits appeal in issue of first impression before Supreme Court of Virginia.
- Representation of chief executive of international sports governing body in connection with investigations led by the U.S. Department of Justice (DOJ) and the Swiss Office of the Attorney General (OAG), and represent the client in related litigation, including before the Court of Arbitration for Sport (CAS) in Lausanne, Switzerland.
- Advised broker-dealer on anti-money laundering (AML) and customer identification program (CIP) compliance program.
- Represented government official related to unauthorized disclosure of financial policy information.
- Performed independent review of anti-money laundering (AML) and Bank Secrecy Act (BSA) compliance program in place at international, publicly traded casino.
- Defended senior executive of Fortune Global 10 multinational energy company in connection with investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC), and in related civil litigation.
- Represented senior executive in multidistrict litigation related to environmental contamination and in connection with congressional inquiries, including testimony.
- Represented Fortune 500 aerospace and defense company as appellant and appellee in companion appeals before the Supreme Court of Virginia.
- Counseled international medical device manufacturer in connection with pre-merger FCPA compliance audit.
- Represented publicly traded wireless carrier in active litigation with the Consumer Financial Protection Bureau (CFPB) and in broader government investigations by the Federal Communications Commission (FCC) and a committee of State Attorneys General.
- Defense of individuals in connection with potential violations of Federal election laws in investigations conducted by the Federal Election Commission (FEC) and the DOJ Office of Public Integrity into so-called straw donor contributions (FECA Section 441f).
- Representation of multinational bank in investigations and litigation involving the DOJ, SEC, Office of the Comptroller of the Currency (OCC) stemming from a multi-billion Ponzi scheme.
- Conducted numerous internal investigations in response to whistleblower allegations.
- Performed FCPA audit and analysis on behalf of multinational agricultural company.
- Represented senior executive of multinational energy company in connection with an SEC FCPA investigation into allegations of corrupt payments made in Russia and Ukraine.
- Anti-Bribery & Anti-Corruption (FCPA)
- Bank Defense and Counseling
- Bank Secrecy Act and Anti-Money Laundering Counseling and Defense
- Commercial Litigation
- Educational Institutions Investigations
- Financial Services Litigation
- Government Investigations & White Collar Litigation
- International Investigations & Enforcement
- Political Investigations Litigation and Enforcement
- Virginia
Named to “Pro Bono Service Honor Roll,” Virginia Access to Justice Commission, 2022
Named to “Virginia Rising Stars,” Criminal Defense: White Collar, Appellate, Super Lawyers, Thomson Reuters, 2012, 2013
- Speaker, "When Compliance Programs Fail: Truth and Consequences," Compliance in the Real World: A Practical Discussion About Today’s Top Issues, McGuireWoods LLP Conference, May 17, 2017
- Speaker, "Recapping and Forecasting Anticorruption Enforcement Trends," SEC Compliance and Disclosure Update, McGuireWoods LLP SEC Practice Complimentary Webinar Series, March 7, 2017
- Panelist, "Know Your Customer and Source of Wealth: Challenges of Third Party Transactions & Foreign Patrons," 2016 Bank Secrecy Act Conference, State Bar of Nevada, May 17, 2016
- Presenter, Casinos and Financial Crime Compliance, ACFCS Webinar, February 10, 2016
- Hon. Donald W. Lemmons, Supreme Court of Virginia, 2009-2010
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University of Richmond School of LawJD
summa cum laude
2009 - University of VirginiaBA1997
Executive Committee Member, Lewis F. Powell, Jr. American Inn of Court
- Spanish
- Author, Federal District Court Declares Corporate Transparency Act (CTA) Unconstitutional, Subject to Inquiry, March 4, 2024
- Author, FinCEN Issues Access Rule Compliance Guide for Beneficial Ownership Information, Subject to Inquiry, February 22, 2024
- Author, New York LLC Transparency Act Beneficial Ownership Reporting Requirements to Take Effect, Subject to Inquiry, January 29, 2024
- Author, Corporate Transparency Act: Three Updates for January 2024, Subject to Inquiry, January 3, 2024
- Author, FinCEN Extends Time to File Beneficial Ownership Information for Entities Created After January 1, 2024, Subject to Inquiry, November 29, 2023
- Author, FinCEN Specifies When and How Reporting Companies May Use FinCEN Identifiers, Subject to Inquiry, November 13, 2023
- Author, Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act, Subject to Inquiry, November 2, 2023
- Author, DOJ Announces Program Incentivizing Clawbacks of Compensation, Subject to Inquiry, March 6, 2023
- Author, At Long Last, FinCEN Issues Beneficial Ownership Information Reporting Rule, Subject to Inquiry, September 29, 2022
- Author, FinCEN’s Proposed Foreign Affiliate SAR Sharing Program — Key Considerations, Subject to Inquiry, January 27, 2022
- Author, FinCEN Comments on New Guidance for Section 314(b) Information-Sharing Program, Subject to Inquiry, December 30, 2020
- Author, Congressional Investigations: A Month In, Congress Signals Close Scrutiny of CARES Act and Paycheck Protection Program, Subject to Inquiry, May 1, 2020
- Author, FinCEN Issues Statement to Financial Institutions on BSA/AML Compliance During COVID-19 Pandemic, Subject to Inquiry, March 18, 2020
- Author, What the Venezuela Sanctions May Mean for Future Sanctions Programs, Subject to Inquiry, March 11, 2019
- Author, SEC Opens Cease-and-Desist Order Proceeding against Broker-Dealer and Chief Compliance / AML Officer, Subject to Inquiry, March 13, 2017
- Author, FinCEN Opens 2017 with SAR Sharing Guidance for Casinos, Subject to Inquiry, January 9, 2017
- Author, FinCEN Associate Director for Enforcement Delivers Remarks at Title 31 Conference, Stresses Importance of Culture of Compliance, Subject to Inquiry, September 21, 2016
- Author, Casino AML: FinCEN Fines Former Sparks Nugget Management $1 Million, Subject to Inquiry, April 7, 2016
- Author, CFPB Announces Two-Year Policy Priorities, McGuireWoods Legal Alert, March 15, 2016
- Author, FinCEN Announces First Card Club AML Enforcement Action, Subject to Inquiry, January 11, 2016
- Co-author, "FinCEN’s Caesars Penalty A Cautionary Tale For Casinos," Law360, September 17, 2015
- Author, FinCEN Announces Caesars Penalty After Multiyear Investigation, Subject to Inquiry, September 11, 2015
- Co-author, "Tinian Dynasty Case Provides A Few Reminders For Casinos," Law360, August 10, 2015
- Author, Casino Forfeiture a Reminder that FinCEN’s Regulatory Oversight May Involve DOJ and Criminal Penalty, Subject to Inquiry, July 31, 2015
- Author, FinCEN Reasserts its Commitment to Casino Oversight and Enforcement, Subject to Inquiry, July 6, 2015
- Author, AML Compliance Developments in the Gaming Industry, Subject to Inquiry, April 28, 2015
- Author, Guilty Plea in DOJ’s First Criminal Prosecution for Campaign Finance Coordination, Subject to Inquiry, February 23, 2015
- Author, "DOJ, SEC Inquiry into Och-Ziff Capital “Placement Fee” Payment Highlights Continuing FCPA Scrutiny," Main Justice, January 9, 2015
- Author, Unpacking OFAC’s Revised Guidance Regarding its “50 Percent Rule”, Subject to Inquiry, August 21, 2014
- Author, "Obstruction of (Contemplated) Justice: Are We About to See the Rise of 18 U.S.C. § 1519?," Business Crimes Bulletin, August 2014
- Author, Obstruction of (Contemplated) Justice, Subject to Inquiry, April 1, 2014
- Author, The Bedeviling Question of Willfulness in the Criminal Context, Subject to Inquiry, February 19, 2014
- Author, Despite Public Perception, Financial Institutions Have Not Received Favored Treatment, Subject to Inquiry, March 26, 2013
- Author, "Genetic Information Nondiscrimination Act of 2008," July 9, 2008