Photo of 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 (DOJ), Criminal Division’s Money Laundering and Asset Recovery Section (MLARS), focuses her practice on white collar criminal defense, government and internal investigations, and anti-money laundering (AML) and international corruption matters.

Kyle was one of 19 prosecutors selected by Robert S. Mueller III to conduct the high-profile investigation into alleged Russian election interference, coordination between Russian officials and the Trump campaign, and related matters. As Assistant Special Counsel, Kyle played a lead role in federal tax and bank fraud investigations, as well as a money laundering investigation into the funding of Russian intelligence cyber intrusions during the 2016 Presidential election using cryptocurrency.

While at the Department of Justice, Kyle was involved in investigations relating to major international money laundering and corruption matters, including matters involving the Bank Secrecy Act (BSA), Foreign Corrupt Practices Act (FCPA), and foreign banking and corruption laws designated as predicates to U.S. money laundering charges. Kyle has considerable experience handling cross-border issues and coordinating with foreign law enforcement authorities and U.S. and foreign regulators on complex transnational financial cases.

Kyle has also represented dozens of federal agencies in high-profile litigation, including the Office of Foreign Assets Control (OFAC), the Department of Defense, and the Federal Financing Bank. Kyle has appeared before federal trial courts across the country.

Admitted in California. Practice in the District of Columbia limited to matters and proceedings before Federal courts and Agencies.

Yesterday, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published responses to three frequently asked questions (“FAQs”) regarding customer due diligence requirements for “covered financial institutions” (
Continue Reading FinCEN Issues FAQs Regarding Customer Due Diligence Requirements

As another sign of the times, but arguably quite apt given the subject matter, the Consensus Blockchain Conference convened virtually in 2020, with Financial Crimes Enforcement Network (FinCEN) Director Ken


Continue Reading FinCEN Director Confirms Enforcement Focus on Virtual Currency AML Compliance

In the last decade, traditional financial institutions such as banks and broker-dealers have faced increased scrutiny from federal regulators and prosecutors related to the adequacy of their anti-money laundering (AML)
Continue Reading AML Compliance Scrutiny of Virtual Currency Services in 2020 and Beyond

On Feb. 10, 2020, the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN) published administrative ruling FIN-2020-R001, to clarify requirements of financial institutions reporting on currency transactions


Continue Reading FinCEN Ruling Clarifies Currency Transaction Report (CTR) Filing Obligations of Financial Institutions