Jeff is co-leader of the firm’s Banking Regulation & Enforcement Practice Group and a senior member of the Government Investigations & White Collar Bank Defense & Counseling and Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) teams. Jeff focuses primarily on the federal Bank Secrecy Act and related state laws and regulations governing financial institutions, including banks, money services businesses (MSBs), and casinos. He regularly represents financial institutions in connection with BSA/AML obligations, including in regulatory and law enforcement investigations, examinations, and day-to-day compliance obligations. Jeff has represented clients in investigations and/or enforcement actions involving the U.S. Department of Justice (DOJ), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), Financial Crimes Enforcement Network (FinCEN), Consumer Financial Protection Bureau (CFPB) and nearly two dozen state financial regulators and attorneys general.
Jeff draws counsels clients by drawing on his broad experience in AML matters – everything from federal registration and state licensing issues, ongoing compliance, independent reviews of AML programs, defending clients in investigations brought by federal or state regulators, and partnering with client consultants on maximizing efficacy of the compliance function.
Leveraging his Spanish-language capabilities, Jeff has conducted Foreign Corrupt Practices Act (FCPA), Foreign Agents Registration Act (FARA), and other investigations in Spain, Mexico and South America. He also regularly represents Spanish-speaking clients in various pro bono matters related to immigration status, custody, and employment matters.
Prior to joining the firm, Jeff served as a law clerk to the Honorable Donald W. Lemons, Chief Justice of the Supreme Court of Virginia, from 2009 to 2010. Jeff also spent several years as a corporate financial analyst covering the media, entertainment, and telecommunications industries at Merrill Lynch & Co. in New York. And, prior to law school, Jeff performed stand-up comedy on CBS late night television.
Experience
Anti-Money Laundering
- Represented national bank in connection with money laundering investigation conducted by U.S. Attorneys Offices and DOJ’s Money Laundering and Asset Recovery Section (MLARS).
- Represented fintech in state licensing enforcement action and licensing application process.
- Successfully challenged Customers & Border Protection (CBP) seizure of currency from MSB on grounds it was engaged in unlicensed money transmission.
- Defended MSB in connection with multi-state examination.
- Advised international financial-institution service provider in connection with FinCEN inquiries and MSB registration process.
- Counseled dozens of clients regarding obligations under the Corporate Transparency Act (CTA), a product of the Anti-Money Laundering Act of 2020.
- Developed training for Legal and Compliance teams of leading fintech company on BSA/AML obligations and risks.
- Advised broker-dealer on AML and customer identification program (CIP) compliance program.
- Performed independent review of BSA/AML compliance program in place at international, publicly traded casino.
Additional Representative White Collar Matters
- Led many internal investigations into whistleblower complaints at national banks.
- Defended national bank against allegations of discrimination against Spanish-speaking home lending customers.
- Represented chief executive of international sports governing body in connection with investigations led by the U.S. DOJ and foreign governments.
- Represented individual client in FARA criminal investigation and prosecution.
- Conducted internal investigations and represented numerous private secondary schools and nonprofit entities in connection with allegations of sexual abuse.
- Defended senior executive of Fortune Global 10 multinational energy company in connection with investigations by the DOJ and the Securities and Exchange Commission (SEC), and in related civil litigation.
- Counseled international medical device manufacturer in connection with pre-merger FCPA compliance audit.
- Represented national bank in investigations and litigation involving DOJ and federal bank regulators stemming from a multi-billion Ponzi scheme.
- Anti-Bribery & Anti-Corruption (FCPA)
- Bank Defense and Counseling
- Bank Secrecy Act and Anti-Money Laundering Counseling and Defense
- Educational Institutions Investigations
- Financial Services Litigation
- Government Investigations & White Collar Litigation
- International Investigations & Enforcement
- Political Investigations Litigation and Enforcement
- Virginia
Named to “Pro Bono Service Honor Roll,” Virginia Access to Justice Commission, 2022
Named to “Virginia Rising Stars,” Criminal Defense: White Collar, Appellate, Super Lawyers, Thomson Reuters, 2012, 2013
- Speaker, "When Compliance Programs Fail: Truth and Consequences," Compliance in the Real World: A Practical Discussion About Today’s Top Issues, McGuireWoods LLP Conference, May 17, 2017
- Speaker, "Recapping and Forecasting Anticorruption Enforcement Trends," SEC Compliance and Disclosure Update, McGuireWoods LLP SEC Practice Complimentary Webinar Series, March 7, 2017
- Panelist, "Know Your Customer and Source of Wealth: Challenges of Third Party Transactions & Foreign Patrons," 2016 Bank Secrecy Act Conference, State Bar of Nevada, May 17, 2016
- Presenter, Casinos and Financial Crime Compliance, ACFCS Webinar, February 10, 2016
- Hon. Donald W. Lemmons, Supreme Court of Virginia, 2009-2010
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University of Richmond School of LawJD
summa cum laude
2009 - University of VirginiaBA1997
Executive Committee Member, Lewis F. Powell, Jr. American Inn of Court
- Spanish
- Author, Treasury Department Formally Exempts U.S. Companies from CTA, Subject to Inquiry, March 24, 2025
- Author, Treasury Department Declares Intent to Limit CTA to Foreign Reporting Companies, Subject to Inquiry, March 3, 2025
- Author, FinCEN’s March 21 CTA Deadline to Report Beneficial Ownership Info Will Not Be Enforced … Yet, Subject to Inquiry, February 28, 2025
- Author, Texas Court Vacates Nationwide Injunction Staying the CTA, Deadline to Report Beneficial Ownership Information is March 21, 2025, Subject to Inquiry, February 19, 2025
- Author, CTA: Despite High Court Order, Companies’ Beneficial Ownership Info Reporting Remains on Hold, Subject to Inquiry, January 24, 2025
- Author, DOJ Seeks Supreme Court Review of CTA Injunction, Subject to Inquiry, January 17, 2025
- Author, Corporate Transparency Act Reporting Obligations: On Hold Until At Least Late March 2025, Subject to Inquiry, January 9, 2025
- Author, Here We Go Again – Fifth Circuit Lifts the CTA Order Lifting the Injunction, Subject to Inquiry, December 27, 2024
- Author, Reporting Companies Have Less Than Three Weeks to File Beneficial Ownership Info With FinCEN, Subject to Inquiry, December 24, 2024
- Author, Federal District Court Issues Nationwide Preliminary Injunction Against Enforcement of the Corporate Transparency Act, Subject to Inquiry, December 4, 2024
- Author, Deadline to Determine Corporate Transparency Act Reporting Obligations Fast Approaching, Subject to Inquiry, December 2, 2024
- Author, Highlights from the 2024 SIFMA Anti-Money Laundering and Financial Crimes Conference on the Corporate Transparency Act, Subject to Inquiry , May 8, 2024
- Author, Federal District Court Declares Corporate Transparency Act (CTA) Unconstitutional, Subject to Inquiry, March 4, 2024
- Author, FinCEN Issues Access Rule Compliance Guide for Beneficial Ownership Information, Subject to Inquiry, February 22, 2024
- Author, New York LLC Transparency Act Beneficial Ownership Reporting Requirements to Take Effect, Subject to Inquiry, January 29, 2024
- Author, Corporate Transparency Act: Three Updates for January 2024, Subject to Inquiry, January 3, 2024
- Author, FinCEN Extends Time to File Beneficial Ownership Information for Entities Created After January 1, 2024, Subject to Inquiry, November 29, 2023
- Author, FinCEN Specifies When and How Reporting Companies May Use FinCEN Identifiers, Subject to Inquiry, November 13, 2023
- Author, Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act, Subject to Inquiry, November 2, 2023
- Author, DOJ Announces Program Incentivizing Clawbacks of Compensation, Subject to Inquiry, March 6, 2023
- Author, At Long Last, FinCEN Issues Beneficial Ownership Information Reporting Rule, Subject to Inquiry, September 29, 2022
- Author, FinCEN’s Proposed Foreign Affiliate SAR Sharing Program — Key Considerations, Subject to Inquiry, January 27, 2022
- Author, FinCEN Comments on New Guidance for Section 314(b) Information-Sharing Program, Subject to Inquiry, December 30, 2020
- Author, Congressional Investigations: A Month In, Congress Signals Close Scrutiny of CARES Act and Paycheck Protection Program, Subject to Inquiry, May 1, 2020
- Author, FinCEN Issues Statement to Financial Institutions on BSA/AML Compliance During COVID-19 Pandemic, Subject to Inquiry, March 18, 2020