On Dec. 13, 2022, the Department of Justice announced that Danish global financial institution Danske A/S (Danske Bank) pled guilty and agreed to forfeit $2 billion to resolve an investigation into fraudulent representations it made to U.S. banks about its anti-money laundering (AML) controls in Estonia. As part of a parallel proceeding, the SEC also announced that Danske Bank agreed to pay $413 million to settle charges for misleading investors about its Estonian AML compliance program and failing to disclose risks posed by the program’s deficiencies.

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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

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.

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.

Photo of Linda Ricci Linda Ricci

Linda M. Ricci focuses her practice on white collar criminal defense, including matters related to corporate compliance and internal investigations, government investigations, money laundering violations, criminal tax offenses, forfeiture, wire fraud, securities fraud, theft of public funds, obstruction of justice, insider trading, and…

Linda M. Ricci focuses her practice on white collar criminal defense, including matters related to corporate compliance and internal investigations, government investigations, money laundering violations, criminal tax offenses, forfeiture, wire fraud, securities fraud, theft of public funds, obstruction of justice, insider trading, and health care fraud.

Linda draws from more than 15 years of experience working for the U.S. Attorney’s Office for the District of Massachusetts, where she served as Chief of the Narcotics and Money Laundering Unit and was a member of the Economic Crimes Unit. During her tenure with the U.S. Attorney’s Office, she represented the United States in all aspects of prosecution, including jury trials, detention hearings, evidentiary hearings, change-of-plea hearings, sentencing hearings, and grand jury proceedings, and she helped develop enforcement strategies and policy guidance in the District of Massachusetts and the New England region. Linda served as the lead prosecutor for several complex international cases resulting in the extradition and prosecution of many foreign nationals on money laundering and drug trafficking charges. She also oversaw the office’s criminal narcotics and money laundering investigations focused on the disruption and dismantling of multi-jurisdictional and international drug trafficking organizations and money laundering organizations. She has worked with a large number of federal agencies, including the Federal Bureau of Investigation, the Internal Revenue Service, Criminal Investigation Division, the United States Postal Inspection Service, the United States Secret Service, the Drug Enforcement Administration, and the Department of Homeland Security, Homeland Security Investigations, as well as numerous state and local agencies.

Photo of Steven E. Harrison Steven E. Harrison

Steven E. Harrison is a member of the Litigation Practice in Greenberg Traurig’s Washington, D.C. office. He represents individuals and businesses in government investigations, complex civil litigation, and white collar criminal matters, including those related to the Foreign Corrupt Practices Act (FCPA), money…

Steven E. Harrison is a member of the Litigation Practice in Greenberg Traurig’s Washington, D.C. office. He represents individuals and businesses in government investigations, complex civil litigation, and white collar criminal matters, including those related to the Foreign Corrupt Practices Act (FCPA), money laundering, wire fraud, and bribery.

As a former Assistant District Attorney, Steven Harrison has substantial experience prosecuting a wide variety of criminal offenses from pre-arrest investigation to trial.