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

Speaker(s): Elizabeth T. Davy, Evelyn Sheehan, Mary Butler, Mia Levine, Michael J. McCullough, Peter Hardy, Tess Davis
Recorded on: May. 11, 2021
PLI Program #: 306564

Evelyn B. Sheehan is a partner at the Miami office of Kobre & Kim, focusing on advising high-net-worth individuals, institutional clients and their executives in cross-border investigations, government enforcement actions and related asset forfeiture matters. She also counsels clients in global asset tracing investigations and recovery efforts.

Before joining Kobre & Kim, Evelyn served at the U.S. Department of Justice as an Assistant U.S. Attorney in the Southern District of Florida. Most recently, she served as Deputy Chief of the Asset Forfeiture Division for that office, responsible for overseeing complex cross-border investigations related to international corruption, white-collar fraud, organized crime and violations of anti-money laundering laws.

At the DOJ, Evelyn was also a member of the Regional Committee of the Organized Crime and Drug Enforcement Task Force (OCDETF). As a result of her work on two high-profile international money laundering investigations, she earned two National OCDETF Awards. Evelyn has also lectured extensively on the application of asset forfeiture and money laundering laws for the DOJ and other federal agencies, including the Federal Bureau of Investigation, the U.S. Department of Defense, the U.S. Department of Health and Human Services, and the Drug Enforcement Agency.

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.         

Mia Levine is currently the Bank Secrecy Act Officer and Head of US Anti-Money Laundering (AML) in the Global AML function at TD Bank Group.  Mia joined TD in February 2014, first serving as the Head of the US AML Financial Intelligence Unit.

Previously, Mia was with the federal government for 17 years, as a prosecutor and as a supervisor with the Asset Forfeiture and Money Laundering Section/Criminal Division at the U.S. Department of Justice. There, she handled a wide variety of financial crime prosecutions, including complex fraud and money laundering, Bank Secrecy Act and IEEPA cases.  Mia concluded her government career by spending three years, part of which as the Chief of Staff, with the Office of the Special Inspector General for the Troubled Asset Relief Program (TARP), an independent agency within the U.S. Department of the Treasury established to prevent fraud, waste and abuse linked to TARP.

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.

Peter Hardy is a Partner in the White Collar Defense/Internal Investigations Practice Group of the law firm of Ballard Spahr LLP, in Philadelphia, PA.  He is a co-leader of Ballard Spahr’s Anti-Money Laundering Team, and he edits and is a frequent contributor to Ballard Spahr's financial corruption blog, Money Laundering Watch.  Peter is the author of a legal treatise entitled Criminal Tax, Money Laundering, and Bank Secrecy Act Litigation (Bloomberg BNA 2010).  Peter also serves on the Steering Committee of the Cambridge Forum on Sanctions & AML Compliance.

Before entering private practice, Peter served for a combined 11 years as an Assistant United States Attorney for the U.S. Attorney’s Office in Philadelphia, and previously as a Trial Attorney in the Criminal Section for the Department of Justice’s Tax Division in Washington, D.C.  Peter graduated from the University of Michigan Law School and served as a law clerk for federal judges in the Eastern District of Michigan and the Court of Appeals for the Sixth Circuit.

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.

Beth Davy is a partner in the Financial Services and Financial Services Litigation and Investigations Groups and is co-head of the Economic Sanctions and Financial Crime Group. Her practice focuses on bank regulation and supervision, regulatory enforcement matters and internal investigations.

Ms. Davy is widely recognized as a leading expert in the areas of anti-money laundering and economic sanctions compliance and enforcement. She has represented numerous financial institutions in high profile global investigations involving multiple U.S. government agencies, as well as public and non-public regulatory enforcement matters. Chambers USA notes that Ms. Davy is “praised for her extensive experience of enforcement actions and internal investigations” and that their sources “call her ‘a fantastic lawyer,’” adding that she is “excellent on execution and strategy.”

Ms. Davy represents various financial institutions in the formation of industry utilities to enhance AML compliance. She has also worked with trade associations and industry representatives on establishment of industry standards and guidelines in the AML and sanctions compliance area and in the evolution of heightened transparency in the international payments system. She is a frequent speaker on issues relating to AML and economic sanctions.