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.

On Dec. 26, 2024, the nationwide preliminary injunction that a Texas district court issued in Texas Top Cop Shop, Inc. v. Garland against enforcement of the Corporate Transparency Act (CTA)

Continue Reading CTA Update: Nationwide Preliminary Injunction Against CTA Reinstated

A Texas district court has issued a nationwide preliminary injunction four weeks before a key Jan. 1, 2025, reporting deadline for the Corporate Transparency Act (CTA) that, while in effect

Continue Reading Texas Court Blocks CTA Nationwide 4 Weeks Before Key Reporting Deadline

On Sep. 4, 2024, FinCEN published a final rule (Final Rule) adding certain RIAs and ERAs (collectively, Covered Advisers) to the definition of “financial institution” under the regulations

Continue Reading FinCEN Adopts New Anti-Money Laundering Program, Recordkeeping and Reporting Requirements for Certain Investment Advisers

The Corporate Transparency Act (CTA) has been in effect since Jan. 1, 2024, requiring non-exempt U.S. entities and non-exempt foreign entities that are registered to do business in the United

Continue Reading CTA Countdown: Upcoming FinCEN Filing Deadlines

On June 28, 2024, FinCEN issued a Proposed Rule to amend BSA regulations that prescribe the minimum requirements for AML/CFT programs for “financial institutions.” Financial institutions subject to AML/CFT program

Continue Reading FinCEN, Federal Banking Agencies Propose Rules to Amend Financial Institutions’ AML/CFT Program Requirements

The CTA mandates that, starting on Jan. 1, 2024, certain U.S. legal entities and foreign entities registered to do business in the United States (collectively, Reporting Companies) disclose certain BOI

Continue Reading FinCEN Issues FAQs on Dissolved Entities’ Beneficial Ownership Reporting Requirements

On March 1, 2024, Judge Liles C. Burke of the U.S. District Court for the Northern District of Alabama found the Corporate Transparency Act (CTA or Act) unconstitutional on the

Continue Reading District Court Declares Corporate Transparency Act Unconstitutional

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has long recognized non-financed (i.e., “all-cash”) transfers of residential real estate as susceptible of money laundering because these methods

Continue Reading FinCEN Proposes Rulemaking Imposing New Residential Real Estate Reporting Requirements