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Anti-Money Laundering 2018: Risks, Due Diligence and Compliance in an Evolving Legal and Technological World


Speaker(s): Adam G. Safwat, Amelia Childress, Eunjung Park, Grant Rabenn, Jeffrey B. Schenk , Kenneth P. Herzinger, Melissa Strait, Nicole S. Healy
Recorded on: Jun. 11, 2018
PLI Program #: 221518

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.

Experience

  • 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.


Amelia Childress is a Compliance Lead at Square, Inc where she is leading Compliance teams dedicated to Square Capital, Square’s international markets, as well as those focused on Governance, Product Management, and Testing and Monitoring. Amelia has worked in numerous roles for traditional financial institutions in due diligence and financial crimes prior to joining Square in 2012. During her time at Square she has helped build out various areas of their financial crimes program and advise business lines on new product development. Amelia was also Head of Compliance at Fundbox, an online lending startup for small businesses, where she spent two years ensuring the company met the rigorous regulatory requirements in the lending space and launching its bank partnership. She graduated from the Monterey Institute for International Studies with a master's degree in International Policy and a Certificate in Nonproliferation Studies.


Eunjung Park, Esp is Vice President in Financial Crimes Compliance at the Agricultural Bank of China, New York Branch.

She focuses on resolving regulatory remediation issues around financial crimes compliance. She designs and delivers training to the Front Office and Back Office staff on BSA/AML and OFAC compliance program, including effective KYC procedures and controls, and sanctions red flags. Previously, she worked at Societe Generale Corporate and Investment Banking in New York City, where she focused on correspondent banking transaction monitoring.

Prior to her career in compliance, she worked at the African Development Bank in Tunis, Tunisia, and focused on deploying loans to African financial institutions and financial infrastructure projects, and increasing financial inclusion.

She holds New York State Bar, and obtained Juris Doctor degree at American University, Washington College of Law in Washington, DC. She obtained her Bachelors of Art in Government at Cornell University in Ithaca, New York.


Grant Rabenn has been an assistant U.S. Attorney in the Eastern District of California since 2011.  He is in the white collar unit and manages a task force focused on prosecuting money laundering and Bank Secrecy Act violations.  Grant has also developed one of the leading dark-web and digital currency practices in the country, having prosecuted dozens of dark-web drug vendors and digital currency money launderers.  Grant was one of the lead attorneys on the investigation and takedown of AlphaBay, the largest dark-web marketplace to have ever existed.  Grant regularly lectures law enforcement and the banking sector on money laundering and BSA issues, and has authored guidance papers for the Department of Justice on those issues.  Grant is also the public corruption coordinator for his office.  Before joining the Justice Department, Grant litigated white collar and asset recovery matters at Kobre & Kim LLP.  Grant is a graduate of the Georgetown University Law Center, cum laude, and the University of California, Los Angeles, magna cum laude


Jeff Schenk has been an Assistant United States Attorney in the Northern District of California for ten years.  He currently serves as Senior Litigation Counsel for the Office.  His practice focuses on white-collar prosecutions.  Before moving to Northern California, Jeff served as a Special Assistant United States Attorney in San Diego.

Jeff has tried eleven cases to verdict as a federal prosecutor, including tax evasion, money laundering, and other financial fraud. In 2016, Jeff tried U.S. v. Pacific Gas & Electric Co., a prosecution resulting from PG&E’s fatal natural gas pipeline explosion in San Bruno, California.

Jeff received his B.A. from the University of Michigan in 2001.  He received his J.D. in 2004 from Boston University School of Law, where he served as Note Editor of the International Law Journal.


Melissa Strait is the US Compliance Officer for Stripe, Inc. Prior to joining Stripe in early 2016, she was a Compliance Operations Manager for Square, Inc. At Square, she oversaw teams in San Francisco and St. Louis which handled transaction monitoring, KYC and EDD reviews, and sanctions screening. Melissa joined Square in 2013 from Kroll, Inc., where she was a Director in the Due Diligence practice. In that capacity, she managed teams producing in-depth due diligence research reports for banking and corporate clients, focused mainly in Asia and the Americas. She graduated from American University with degrees in International Studies and Spanish.


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.


Ken Herzinger is the Chair of the White Collar, Investigations, Securities Litigation and Compliance Group and a partner in the San Francisco office. Ken was an attorney in the Enforcement Division of the U.S. Securities and Exchange Commission prior to joining private practice. His practice focuses on SEC investigations and enforcement actions, internal investigations, securities class actions, and ERISA class actions.

Ken has 20 years of experience as a securities litigator and has handled every type of SEC investigation and securities case, including new and developing areas like cybersecurity, blockchain, cryptocurrency, and SEC BSA/AML enforcement, and more traditional matters such as accounting and financial reporting, internal control over financial reporting (ICFR), disclosure controls and procedures, the Foreign Corrupt Practices Act (FCPA), insider trading, and Dodd-Frank and SOX whistleblower retaliation claims.