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Anti-Money Laundering 2019: Risks, Due Diligence and Compliance in an Evolving Legal and Technological World

Speaker(s): David Szuchman, Jamie Boucher, Karen D. Beausey, Matthew Moses, Michael A. Mancusi, Nicole S. Healy, Ryan Fayhee
Recorded on: Jun. 10, 2019
PLI Program #: 252926

Jamie Boucher is head of Skadden’s Financial Institutions Regulatory and Enforcement Group and the global anti-money laundering and sanctions practice. Her clients include U.S. and international banks, thrifts, mortgage lenders, insurance, securities, money service businesses and investment companies.

Ms. Boucher, a member of the practice group named 2018 White Collar/Regulatory Litigation Department of the Year by The American Lawyer, regularly represents global financial institutions on complex cross-border compliance and enforcement matters including examinations, internal investigations, voluntary disclosures, and the resolution of administrative and enforcement proceedings involving federal and state regulatory agencies and law enforcement.

With extensive experience in cross-border anti-money laundering, economic sanctions, banking secrecy and data protection compliance matters, Ms. Boucher has counseled U.S. and international clients on numerous issues arising under the U.S. anti-money laundering and economic sanctions laws and related laws.

In addition to the representation of clients in investigations and contested proceedings, Ms. Boucher regularly works with financial institutions and their boards to provide guidance on compliance and corporate governance issues. She has worked extensively with clients to design and implement compliance programs, and to monitor and improve corporate compliance posture.

She also has represented clients on various aspects of federal lending, capital and liquidity support programs, including those established pursuant to the Emergency Economic Stabilization Act of 2008. She additionally advises clients on the implementation of the Dodd- Frank Act and strategic transactional and compliance responses to the Act.

Ms. Boucher is a frequent speaker at seminars on financial institution compliance and regulatory issues, mergers and acquisitions, and enforcement matters. She repeatedly has been selected for inclusion in Chambers USA: America’s Leading Lawyers for Business and The Best Lawyers in America, as well as in Washingtonian Magazine’s Best Lawyers list for her work in banking and regulatory enforcement matters. She was named a finalist in the Regulatory Lawyer of the Year category at the inaugural Chambers USA Women in Law Awards. Ms. Boucher also has repeatedly been named in Lawdragon 500 Leading Lawyers in America and as Best Lawyers’ 2019 Washington, D.C. Litigation - Banking and Finance Law Lawyer of the Year.

Before joining the firm, Ms. Boucher worked for 12 years in government and the private sector on matters involving international trade and investment regulation. She served as the legislative adviser for international trade and foreign policy to former U.S. Sen. Frank H. Murkowski; an adviser to the American League for Exports and Security Assistance on trade and national security issues; and a committee staff member on the U.S. Trade Representative-Department of Defense trade policy advisory committee, the Defense Policy Advisory Committee on Trade.

Ms. Boucher serves on the American Bar Association Task Force on Anti-Money Laundering Compliance in the Legal Profession and is the past chair of the Banking Law Committee, Subcommittee on Mergers and Acquisitions. She is a member of the American Council of Young Political Leaders.


Karen Beausey is an AUSA with over 24 years’ experience investigating and prosecuting complex fraud, drug, and money laundering cases.  She has served as an AUSA in the San Francisco US Attorney’s Office for the Northern District of California, and in the Boston US Attorney’s Office for the District of Massachusetts.  She has served as the Chief of the Narcotics/Organized Crime Drug Enforcement Task Force Section and as the OCDETF Regional Coordinator for the Pacific Region. 

In addition, from 2007-2009 Karen served as a Trial Attorney for the United Nations International Criminal Tribunal for the Former Yugoslavia, where she investigated and prosecuted war crimes and crimes against humanity committed in the territory of the Former Yugoslavia. 

Karen graduated from Harvard University and received her JD from Boalt Hall School of Law, University of California at Berkeley.  Prior to becoming a federal prosecutor, Karen worked in private practice in San Francisco and served as a judicial law clerk for the Hon. Thelton E. Henderson, Chief Judge for the United States District Court, Northern District of California. 

Karen is a repeat instructor in Trial Advocacy at the US Department of Justice National Advocacy Center, and a repeat instructor in money laundering and asset forfeiture for the US Department of Justice Money Laundering and Asset Recovery Section. 


Matthew Moses is a partner in Orrick’s New York Office and a member of the White Collar, Investigations, and Compliance Group.

Matt has substantial experience representing financial institutions, corporations, and individuals in connection with government and internal investigations involving the Foreign Corrupt Practices Act (FCPA), the Bank Secrecy Act (BSA) and U.S. anti-money laundering (AML) regulations, U.S. economic sanctions administered by the Office of Foreign Assets Control (OFAC), and fraud-related laws and regulations. He also counsels clients on government-imposed compliance obligations, advising on designing, enhancing, and implementing compliance policies and procedures, conducting regulatory diligence for investments and other deals, and obtaining licenses or other guidance when appropriate.

Matt received his B.A. from Amherst College and his J.D. From New York University School of Law. He also serves on the board of The Legal Aid Society’s New Leadership Program.

Michael Mancusi represents domestic and foreign banks, credit unions, and other financial services clients in a wide range of state and federal regulatory, compliance, and enforcement matters. He also has substantial experience representing clients in government and corporate internal investigations, including entities subject to anti-money laundering requirements.

Mr. Mancusi counsels clients facing complex corporate governance and structural issues and represents clients before key state and federal bank regulatory agencies, including the Office of the Comptroller of the Currency, the Federal Reserve, the FDIC, the National Credit Union Administration, the Financial Crimes Enforcement Network, the Consumer Financial Protection Bureau, and the Office of Foreign Assets Control.

Mr. Mancusi counsels clients on compliance with privacy and data security requirements, including financial privacy under the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, as amended by the Fair and Accurate Credit Transactions Act, and the federal E-Sign Act. In addition, Mr. Mancusi advises clients regarding developing and implementing data breach response programs, including compliance with notification requirements at the federal and state levels.

Recognized by Chambers USA as "a key player in the enforcement arena," Mr. Mancusi served in the Enforcement Division of the Office of the Comptroller of the Currency, where he handled its banking law enforcement actions. He is currently Vice Chair of the ABA's Banking Law Committee, and served on the Executive Council of the Federal Bar Association's Banking Committee. In addition, Mr. Mancusi teaches a training program through the Institute for International Bankers on the US anti-money laundering and sanctions program issues that are most relevant to international banks.

Nicole Healy is a partner in the Redwood City office of Ropers Majeski PC.  Ms. Healy represents companies and individuals in litigation and arbitration involving a wide range of industries in matters concerning corporate governance and control; commercial disputes; shareholder class action and derivative litigation; antitrust violations; False Claims Act litigation; disputes concerning intellectual property rights and trade secrets; and mergers and acquisitions.  She has conducted, and has represented companies and their executives in, corporate internal investigations into possible violations of federal and state law.  Ms. Healy has represented companies and individuals in investigations by the Federal Trade Commission, the Securities and Exchange Commission, U.S. Attorneys’ Offices, and other government agencies.  She has tried cases to judgment in state and federal courts, and to decision in private arbitration proceedings.  Ms. Healy has counseled companies regarding compliance with state and federal laws, including the U.S. Foreign Corrupt Practices Act (“FCPA”), UK Bribery Act, and anti-money laundering laws

In addition to her work as a litigator, Ms. Healy serves as a mediator for the U.S. District Court for the Northern District of California.

Prior to entering private practice, Ms. Healy was a prosecutor for the U.S. Department of Justice, in the Fraud Section, Criminal Division where she focused on violations of the FCPA, defense procurement fraud, and international white-collar criminal matters. 

Ms. Healy is the author of the Anti-Money Laundering Deskbook: a Practical Guide to Law and Compliance (Practising Law Institute, 2020 ed.), as well as numerous articles regarding money laundering and terrorist finance, the FCPA, and other topics, and is a frequent speaker.

Ryan Fayhee is a partner in the Washington, D.C. office of Hughes Hubbard. He leads the Sanctions, Export Controls & Anti-Money Laundering practice group and is a member of the Anti-Corruption & Internal Investigations practice group.

Prior to private practice, Ryan served for 11 years in the U.S. Department of Justice (DOJ), where he was a leading prosecutor handling complex investigations and prosecutions affecting the national security and foreign policy of the United States. He also previously served as the National Export Control Coordinator, the principal DOJ attorney overseeing sanctions and export control prosecutions nationally.

Ryan represents companies, boards of directors, audit committees and senior executives in internal and government facing cross-border investigations and advises clients on compliance and acquisition due diligence with a focus on sanctions, export controls, anti-money laundering, anti-corruption, and cybersecurity. Ryan has significant experience assisting multinational companies facing crises and other high profile reputational risks. Ryan is also an experienced trial lawyer and regularly represents clients in federal court and before the DOJ, federal law enforcement authorities, and trade regulators at the Office of Foreign Assets Control (OFAC), the Bureau of Industry and Security (BIS), and the Directorate of Defense Trade Controls (DDTC).

David Szuchman joined PayPal in August 2016 as VP, Head of Global Financial Crimes Compliance and BSA Officer. In that capacity, David is responsible for designing and overseeing programs to detect and prevent money laundering, terrorism financing, sanctions, and related risks across the company.

Prior to joining PayPal, David was an Executive Assistant District Attorney and Chief of the Investigation Division at the New York County District Attorney’s (DA’s) Office where he was responsible for supervising the Rackets Bureau, Major Economic Crimes Bureau, Cybercrime and Identity Theft Bureau, Counter Terrorism Program, Financial Frauds Bureau, Tax Crimes Unit, Public Corruption Unit and the Asset Forfeiture Unit. Under David’s leadership and supervision, the investigation division initiated and concluded significant cases against numerous large financial institutions). He also assisted the District Attorney with major initiatives such as the Global Cyber Alliance and the efforts surrounding encryption.

Before he became Chief of the Investigation Division in 2012, David served as Chief of the Cybercrime and Identity Theft Bureau for New York County’s DA’s Office assisting in developing policies and investigative strategies, maintaining relationships with outside agencies and helping to supervise investigations throughout the Division.

David began his legal career at the New York County DA’s Office in 1997 and has subsequently held several notable governmental positions including serving as a federal prosecutor assigned to the Child Exploitation and Obscenity Section within the U.S. Justice Department. In 2008, David was appointed as the Director of Consumer Affairs for the State of New Jersey.

David graduated from the University of Vermont with a bachelor's degree in political science, and received a law degree from Hofstra University School of Law.