On Oct. 23, 2020, the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the Federal Reserve System (FRB) (FinCEN and the FRB collectively, the Agencies), issued a joint notice of proposed rulemaking (Proposed Rule) that would amend the Recordkeeping Rule and Travel Rule regulations issued under the Bank Secrecy Act (BSA).

Read the full GT Alert, “FRB and FinCEN Propose Significant Amendments to Recordkeeping and Travel Rule Regulations.”

Tags: banking, banking and financial services, banks, blockchain, BSA, compliance, DOT, financial regulatory and compliance, FinCEN, FRB, Greenberg Traurig, GT Insight, GT Law, regulatory, travel, white collar, white collar defense and special investigations
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Photo of Kyle R. Freeny Kyle R. Freeny

Kyle R. Freeny, a skilled trial attorney and former federal prosecutor for the Special Counsel’s Office and the Department of Justice’s Money Laundering and Asset Recovery Section (MLARS), draws on more than a dozen years of high-profile experience in the federal government to

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Kyle R. Freeny, a skilled trial attorney and former federal prosecutor for the Special Counsel’s Office and the Department of Justice’s Money Laundering and Asset Recovery Section (MLARS), draws on more than a dozen years of high-profile experience in the federal government to help clients navigate sensitive government and internal investigations, criminal and civil enforcement matters, and related complex litigation. She has particular experience in matters involving complex financial crime, cross-border investigations, anti-money laundering, anti-corruption, economic sanctions, asset forfeiture, and affirmative challenges to federal agency action.

While at the Department of Justice, Kyle also played a key role in major international money laundering and corruption matters, including important matters involving the Bank Secrecy Act (BSA) and Foreign Corrupt Practices Act (FCPA). Kyle also has considerable experience handling sensitive and complex cross-border issues in transnational financial cases, and she was responsible for the largest civil asset forfeiture recovery in DOJ history.

Kyle uses this deep experience in federal law enforcement to counsel clients facing scrutiny from DOJ, the Securities and Exchange Commission (SEC), the Financial Crimes Enforcement Network (FinCEN), and other law enforcement and financial regulatory agencies. Kyle conducts internal investigations on a range of issues and advises clients on a wide array of anti-money laundering, anti-corruption, and other compliance issues.

Kyle also helps clients develop and litigate challenges to federal regulations, policies, and agency decisions across a range of industries, drawing on her years of prior experience at DOJ representing a cross-section of federal agencies —from the Office of Foreign Assets Control (OFAC) to the Department of Energy to the Department of State and various intelligence agencies—in high-profile litigation. She has appeared before federal trial courts across the country.

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Photo of Marina Olman-Pal Marina Olman-Pal

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office…

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office of Foreign Assets Control (OFAC) sanctions programs. Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, gaming companies, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies and digital payment companies. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities. Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.

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