Corporate Exposure Under Anti-Money Laundering Enforcement: Mitigating Risk with Strong Compliance Programs

Leah Moushey | Miller & Chevalier

Leah’s practice focuses on internal and government investigations, regulatory defense, and compliance advice on a range of issues, including foreign bribery, money laundering, sanctions and export controls violations, and fraud. She has counseled clients in the context of multi-jurisdictional internal and government-facing investigations, pre- and post-initial public offerings (IPOs), compliance audits, third party due diligence, and M&A due diligence. Leah has extensive experience advising clients across various industries but devotes a substantial portion of her practice to representing companies in the technology and fintech sectors.

Leah has particular experience in counseling clients on issues arising in Latin America and sub-Saharan Africa, having lived and worked in both regions. She is fluent in Portuguese and proficient in Spanish.

Prior to law school, Leah lived in Maputo, Mozambique, where she interned at a non-governmental organization, focusing on issues related to gender-based violence and HIV/AIDS. During law school, Leah served as a legal extern in the U.S. Department of Justice Criminal Division’s Fraud Section, a legal intern at the U.S. District Court for the Western District of Pennsylvania, and an extern at the Mid-Atlantic Innocence Project.

Ian A. Herbert | Miller & Chevalier

Ian Herbert defends global companies, executives, and trustees in high-stakes government investigations and litigation. He handles a broad range of civil litigation and criminal enforcement matters, with a particular focus on complex, cross-border disputes. He has experience with matters involving claims or allegations of Racketeer Influenced and Corruption Organization Act (RICO), trade secret misappropriation, False Claims Act (FCA), bribery, tax fraud, and other fraud.

Mr. Herbert regularly engages with the Department of Justice (DOJ), Securities and Exchange Commission (SEC), and other federal and state regulators. Because his matters are often multijurisdictional, Mr. Herbert is also familiar with the relevant enforcement authorities outside the U.S. and helps clients navigate the complex issues that arise in multi-jurisdictional investigations and litigation. He has extensive experience obtaining U.S. discovery for use in foreign proceedings under 28 U.S.C. § 1782 and has used the statute not only to obtain documents but also to take depositions of individuals and entities throughout the U.S. and around the world.

Part of the firm’s Trust and Family Office and Anti-Money Laundering (AML) practice groups, Mr. Herbert also advises U.S. and foreign companies on anti-money laundering obligations, drafts AML policies, and conducts AML trainings. He assists high-net-worth individuals, trustees, and companies interacting with financial institutions regarding AML inquiries.

Mr. Herbert maintains a robust pro bono practice focused primarily on representing individuals in criminal prosecutions and post-conviction proceedings. In 2017, he briefed, argued, and obtained a reversal of a criminal conviction in the DC Court of Appeals. In 2020, he secured the early release of another client under the First Step Act. In 2024, following years of litigation, he obtained a favorable settlement for a client who had been assaulted while in prison.

Mr. Herbert writes regularly on issues related to white-collar criminal enforcement and AML. He is an editor of the firm’s Money Laundering Enforcement Trends newsletter, which focuses on developments in money laundering regulation and enforcement.

Vanessa Singh Johannes | Foley & Lardner

Vanessa Singh Johannes is a seasoned trial attorney who counsels individuals and corporations on a wide array of civil, criminal, and compliance matters. She offers clients nearly two decades of experience, both as a former federal prosecutor and complex litigator.

For a decade, Vanessa honorably served as an assistant U.S. attorney for the Southern District of Florida, where she tried dozens of jury trials, handled hundreds of criminal and civil investigations, and argued appellate matters before the Eleventh Circuit Court of Appeals. She investigated, indicted, and tried cases involving serious crimes that affected everyday people in the Miami community, large companies, and U.S. taxpayers, including fraud, money laundering, espionage, civil rights, arms trafficking, human trafficking, and murder.

Vanessa’s vast experience as an assistant U.S. attorney lends her unique insight into all phases of government investigations — such as grand jury inquiries, complex search warrants, and mutual legal assistance treaty requests — and reliable knowledge of federal practice in the district. During her tenure, she also developed a close working relationship with federal, state, and local law enforcement agencies, including the U.S. Secret Service, the Bureau of Alcohol, Tobacco, Firearms, and Explosives, Drug Enforcement Agency, Homeland Security Investigations, and the Federal Bureau of Investigation.

In private practice across two major law firms, Vanessa has developed a successful track record handling complex “bet-the-company” cases. She represents companies in an array of civil matters, complex litigation, and crises and assists clients in responding to federal agency inquiries, conducting internal investigations, board presentations, training on relevant laws, and crafting compliance programs to meet legal regulatory and criminal requirements. Armed with her experience as a federal prosecutor, Vanessa also handles complex criminal matters, including those involving the False Claims Act, the Foreign Corrupt Practices Act, wire fraud, and money laundering.

Prior to joining Foley, Vanessa was the co-managing shareholder of a national law firm’s Miami office.

Cary Aronovitz | Holland & Knight

Cary Aronovitz is a Miami trial lawyer and focuses his practice on government investigations, corporate compliance, complex commercial litigation, corporate and consumer fraud investigations, healthcare fraud investigations, and fraudulent transfer litigation and recovery.

In 2022, Mr. Aronovitz and Holland & Knight obtained a jury verdict in excess of $158 million following a four-week jury trial based upon defendants’ fraud and negligent misrepresentations. Mr. Aronovitz handled the direct and cross examinations of nine witnesses, including both parties’ expert witnesses. The jury’s verdict included an award of punitive damages and was the largest jury verdict that year in the state of Florida.

Prior to joining Holland & Knight, Mr. Aronovitz was an Assistant U.S. Attorney for the Southern District of Florida in Miami. In his six years at the U.S. Attorney’s Office (USAO), Mr. Aronovitz tried numerous jury trials before nearly every district court judge in the Southern District of Florida and argued cases before the U.S. Court of Appeals for the Eleventh Circuit. He has indicted and prosecuted hundreds of federal crimes, including money laundering, bank fraud, human trafficking, violent organized gangs, sexual exploitation of minors, mail and wire fraud, aggravated identity theft, armed robberies and cybercrimes involving the dark web. He was also successful in achieving substantial asset forfeiture recoveries for victims, including the recovery of financial assets stolen through fraudulent transfers.

Mr. Aronovitz led several multiagency investigative cases and developed close working relationships with the Federal Bureau of Investigation (FBI), U.S. Postal Inspection Service, IRS Criminal Investigation, U.S. Immigration and Customs Enforcement (ICE) Homeland Security Investigations (HSI), Drug Enforcement Administration (DEA), Miami-Dade Police Department and various local law enforcement agencies. He utilizes these experiences to assist clients in responding to subpoena requests from various government agencies, non-party subpoena requests and issues related to the Stored Communications Act (SCA), and various regulatory statutes.

Mr. Aronovitz was recently recognized by The Best Lawyers in America 2024 guide for Commercial Litigation. He also received the “On The Rise” award in 2023 by the Florida Legal Awards (FLLA), through the Daily Business Review. In 2021, Mr. Aronovitz was named by Florida Trend magazine’s Legal Elite as an Up & Comer for Civil Trial, recognizing him as the top 1.3 percent of Florida lawyers named to Legal Elite.

Prior to joining the USAO, Mr. Aronovitz clerked for the Honorable Alicia O. Valle of the U.S. District Court for the Southern District of Florida. While in law school, he was a member of the University of Florida Moot Court Team and won three moot court competitions, including best oralist in a competition judged by U.S. Supreme Court Chief Justice John Roberts. Mr. Aronovitz is active in the South Florida community, including having previously served as a committee chair to the Dade County Bar Association Legal Line.

Session I – AML Enforcement Trends and Compliance Essentials | 1:00pm – 2:00pm

• Defining money laundering and terrorist financing: Definition of money laundering, its stages, and how it differs from terrorist financing
• The U.S. AML/CFT legal framework: Relevant U.S. laws and regulations
• Responsibilities of financial institutions and businesses: Understanding the obligations of financial institutions in complying with AML laws and regulations and implementing effective compliance programs
• Recent enforcement priorities and consequences of non-compliance: Penalties and risks associated with failing to comply with AML laws and regulations
• Red flags: Strategies for identifying potential money laundering or terrorist financing

Break | 2:00pm – 2:10pm

Session II – Navigating AML Enforcement, Compliance Risks, and Valuation Disputes in Financial Crime Cases | 2:10pm – 3:10pm

• What to expect: The focus on cartels and money laundering under the Trump administration
  • Sentencing enhancements, broad reach, and increased risk by companies doing international business
• Money-laundering statutes, sentencing issues, and criminal and civil penalties
• Evidence utilized by prosecutors to demonstrate money-laundering violations
• How companies can minimize risks with robust compliance measures and proactive diligence
• Red flags and internal controls in high-risk industries
• Valuation disputes in asset forfeiture, loss amount, and restitution