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Anti-Money Laundering 2021: Risks, Due Diligence and Compliance in an Evolving Legal World

Speaker(s): Adam G. Safwat, Mary Butler, Michael J. McCullough, Nicole S. Healy, Sharon Levin, Tess Davis
Recorded on: May. 14, 2021
PLI Program #: 306568

Adam Safwat is counsel in Weil’s White Collar practice and is resident in Weil’s Washington, D.C. office. His practice focuses on white collar criminal defense, regulatory enforcement matters, and internal investigations. He has significant experience in criminal and civil litigation.

Mr. Safwat previously served as a Deputy Chief of the Fraud Section of the U.S. Department of Justice’s Criminal Division from 2012 to 2014. He also served in the Fraud Section as an Assistant Chief from 2008 to 2012 and as a Trial Attorney and Senior Trial Attorney from 2006 to 2008. During his time at the Fraud Section, he worked on a number of significant Foreign Corrupt Practices Act investigations involving companies operating in the commodities, oil services, logistics, and defense industries.  Mr. Safwat was the lead prosecutor in the FCPA prosecution of Alcoa that resulted in a guilty plea of an Alcoa subsidiary and more than $380 million in combined DOJ and SEC penalties in 2014.

In addition, while at the Fraud Section, Mr. Safwat served on several complex securities fraud investigations of individuals and entities in the financial services industry, including matters involving alleged accounting fraud relating to complex derivative instruments and special purpose entities.  Mr. Safwat was one of several senior prosecutors at the Fraud Section tasked with reviewing allegations against Wall Street firms arising from their conduct in the pre-2008 RMBS market.  Mr. Safwat also was a member of the government’s successful trial team in 2008 against five insurance industry executives for their role in manipulating AIG’s financial statements.

Prior to joining the Fraud Section, Mr. Safwat spent almost four years as an Assistant U.S. Attorney in the U.S. Attorney's Office for the District of Delaware, where he conducted jury trials in general crimes cases and also concluded a number of successful white collar investigations in areas such as theft of trade secrets and tax fraud.

Earlier in his career, Mr. Safwat spent approximately six years in private practice in Palo Alto, California, and New York, NY, where he was involved in various complex civil litigation matters, including representation of Time Warner in successfully enjoining the City of New York from imposing a competitor’s news channel on its cable system, and representation of Time Warner in the Delaware Court of Chancery in its successful defense of its rights to acquire the Turner Broadcasting Network.

Mr. Safwat received his J.D. and LL.M. in International Law from the Duke University School of Law, where he graduated Order of the Coif and served as a notes editor of the Duke Law Review. He received his B.A. in Political Science from the University of California, where he graduated with high honors. After graduation, he served as law clerk to the Honorable Walter K. Stapleton of the U.S. Court of Appeals for the Third Circuit in Philadelphia.

Mr. Safwat has been recognized as a “recommended” lawyer nationwide for White Collar Defense by The Legal 500, while Global Investigations Review called him a “name to know” in its inaugural edition of the GIR 100.


  • Conducted an internal investigation on behalf of and represented a global pharmaceutical company in a joint DOJ and SEC investigation of alleged FCPA violations in several countries in Eastern Europe and Asia, and obtained a DOJ declination.
  • Conducted a comprehensive review of a U.S. issuer’s compliance and employment relations internal investigation functions, and issued recommendations to senior management regarding coordination and enhancement of the same.
  • Represented a former senior executive of a major Korean industrial firm in a DOJ and SEC investigation involving alleged FCPA violations arising from transactions in Brazil.
  • Successfully represented a major non-profit organization which overseas employment opportunities for the disabled in federal contracting assignments in a federal criminal investigation concerning the company’s conduct and practices in a federal contract selection process.
  • Counseled a global business solutions provider on FCPA issues in connection with an internal investigation in Europe.
  • Represented numerous acquirers and underwriters in anti-corruption and anti-money laundering due diligence.
  • Has conducted panels for PLI on money laundering issues and has been a speaker on internal investigations at significant conferences, such as the ABA’s London White Collar Institute and the ACI’s FCPA Conference in Washington, D.C.
  • Co-chaired Global Investigation Review’s (GIR) Washington, D.C. Live Conference in October 2018.
  • Quoted by GIR and other publications, including the New York Times, on FCPA and internal investigations matters.
  • Participates in Weil’s pro bono committee work, and supervises attorneys in reviewing cases for the Innocence Project.

Mary Butler is the chief of the International Unit of the Money Laundering and Asset Recovery Section at the U.S. Department of Justice.  As chief, she oversees the Department’s Kleptocracy Asset Recovery Initiative.  The mission of the Initiative is to recover assets linked to foreign corruption that affect the US financial system and to prosecute those involved where appropriate.  An important goal of the Initiative is to return the net recovered assets for the benefit of the people harmed by the corruption through agreements that ensure the transparent and accountable use of the funds. Prosecutors in the International Unit also enforce foreign court restraining and forfeiture orders against assets in the United States involving all crimes and implement the Department’s international asset sharing program.  International Unit prosecutors also participate in the US delegations to FATF and the UNCAC Conference of State Parties, as well as various informal international networks of asset recovery practitioners.  The Unit works closely with the FBI’s International Corruption Unit and special agents of the Department of Homeland Security and Internal Revenue Service Criminal Investigations.    

Mary is a career federal prosecutor.  After working as an associate in private practice in Chicago, Mary worked as an AUSA in the US Attorney’s office in the Southern District of Florida in Miami for 12 years.  After serving as the chief of the Public Corruption Section, she moved to the Public Integrity Section at Main Justice.  From 2011- 2014, Mary served on a detail in Ukraine as a DOJ OPDAT Resident Legal Advisor.  She joined MLARS as the International Unit’s chief in 2014.         

Michael McCullough is a Founding Partner of Pearlstein & McCullough LLP, a law firm providing high-level services to the international art market.

Michael McCullough's art law practice covers a broad area of the art market. He advises galleries, auctioneers, collectors, and museums on a variety of matters regarding consignment agreements, private sale agreement, authenticity issues, ownership issues, and government regulatory issues affecting the art market.

During his ten years as compliance counsel at Sotheby’s, he gained extensive experience in the full range of commercial and regulatory concerns involved in art market transactions.

Mr. McCullough is an Adjunct Professor at Cardozo School of Law where he teaches “Art Law.”

Mr. McCullough is a Member of the Personal Property Resource Panel of the Appraisal Foundation.

Mr. McCullough is also a Senior Advisor and Past-Chair of the Art and Cultural Heritage Law Committee of the American Bar Association.

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.

Sharon Cohen Levin is a partner in Sullivan & Cromwell’s Litigation Group and member of the firm’s Criminal Defense and Investigations Group. Her practice focuses on money laundering and asset forfeiture advice for a diverse group of corporate clients.

Ms. Levin received her B.A. from Tulane University and J.D. from the University of San Diego School of Law.

For nearly two decades prior to entering private practice, Ms. Levin led the Money Laundering and Asset Forfeiture Unit in the U.S. Attorney’s Office for the Southern District of New York. Under her leadership, the SDNY was responsible for nearly 60% of all forfeitures in the United States. Her track record of success inspired Forbes to call her “The Babe Ruth of Forfeiture.” She also led multiple significant prosecutions, working hand in hand with federal banking regulators, the Office of Foreign Asset Control, and other regulatory authorities.

Tess Davis, a lawyer and archaeologist by training, is Executive Director of the Antiquities Coalition. Davis oversees the organization’s work to fight cultural racketeering worldwide, as well as its award-winning think tank in Washington. She has been a legal consultant for the US and foreign governments and works with both the art world and law enforcement to keep looted antiquities off the market. She writes and speaks widely on these issues — having been published in the New York Times, the Wall Street Journal, CNN, Foreign Policy, and top scholarly journals — and featured in documentaries in America and Europe. She is admitted to the New York State Bar, teaches cultural heritage law at Johns Hopkins University, and is a Term Member of the Council on Foreign Relations.

In 2015, the Royal Government of Cambodia knighted Davis for her work to recover the country’s plundered treasures, awarding her the rank of Commander in the Royal Order of the Sahametrei.