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BSA/AML Reform Under the NDAA


Speaker(s): Kevin M. Toomey, Michael A. Mancusi
Recorded on: Mar. 11, 2021
PLI Program #: 321861

Kevin Toomey represents banks and nonbank financial services companies, along with their boards of directors, executives, and senior management, in a wide range of enforcement, regulatory, compliance, and governance matters before the federal and state banking agencies, Department of Justice, CFPB, FinCEN, and OFAC. Mr. Toomey regularly represents clients in investigative proceedings, including navigating internal and
government investigations, and advises clients on issues relating to the Bank Secrecy Act and anti-money laundering requirements, consumer protection, the Dodd-Frank Wall Street Reform and Consumer Protection Act, and state and federal banking laws and regulations.

Mr. Toomey also has significant experience counseling financial institutions on an array of corporate, securities, and transactional matters, including mergers and acquisitions, public and private securities offerings, and corporate reorganizations. While attending law school, Mr. Toomey worked in the Enforcement Section of the FDIC, the Executive Office for US Attorneys at DOJ, and the US Attorney's Office for the District of Columbia.


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.