Jeffrey M. Hanna Partner

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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.


  • 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.