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Targeted Action, Rule Tweaks Reflect 2025 AML Priority Shifts

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Deb Connor, Marc-Alain Galeazzi, and Liz Aloi published an article in Law360 that reviewed the most significant developments in...

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Deb Connor, Marc-Alain Galeazzi, and Liz Aloi published an article in Law360 that reviewed the most significant developments in anti-money laundering enforcement and regulatory action in 2025. The authors discussed the impacts of various Executive Orders, the Brink's Global Services non-prosecution agreement and consent order, shifts in enforcement related to the Corporate Transparency Act, and more.Read the <a href="https://www.law360.com/articles/2424404" target="_blank">full article</a>.

Targeted Action, Rule Tweaks Reflect 2025 AML Priority Shifts

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Deborah L. Connor, former chief of the Money Laundering and Asset Recovery Section (MLARS) of the U.S. Department of Justice (DOJ), is a partner in MoFo’s Investigations + White Collar Defense Group. With more than 25 years of service at DOJ, most recently leading its anti-money laundering (AML)/Bank Secrecy Act (BSA) enforcement, Deborah is a leading authority in criminal AML/BSA matters. Drawing upon her unmatched experience in criminal investigations, litigation, and enforcement, Deborah focuses on guiding financial institutions, multinational companies, and individuals through cross-border internal investigations, regulatory enforcement defense, white collar criminal defense, and compliance counseling involving legal issues pertaining to sanctions, anti-corruption, AML/BSA, and cryptocurrency, among others.As chief and principal deputy chief of MLARS, Deborah supervised investigations and prosecutions of numerous high-profile cases involving allegations of corporate and financial misconduct and resolutions involving deferred prosecution and non-prosecution agreements in relation to financial institutions and emerging technologies in the financial services markets, as well as blockchain-based digital assets. As chief, she exercised supervisory authority over the DOJ’s AML program, specifically any charges involving violations of BSA statutes. Deborah has worked with domestic regulators, including the Financial Crimes Enforcement Network, the Office of the Comptroller of the Currency, the Federal Reserve, and the Office of Foreign Assets Control, as well as enforcement officials throughout the federal government, including the Departments of State, Commerce, and Treasury. She was also responsible for helping to oversee the Department’s Asset Forfeiture Program. Deborah also served as senior counsel to the assistant attorney general for the Criminal Division.Prior to joining the Criminal Division, Deborah had a distinguished 16-year career as an assistant U.S. attorney in the U.S. Attorney’s Office for the District of Columbia, where she held several leadership positions and supervised hundreds of prosecutors. In her last five years with the office, Deborah served as chief of the Fraud and Public Corruption Section, where she supervised the office’s white collar prosecutions including complex AML and sanctions evasion investigations and prosecutions against global financial institutions and their employees, civil and criminal forfeiture cases, and major financial fraud actions involving corporations and government agencies. As a criminal prosecutor, Deborah has investigated a broad range of white collar and other federal criminal matters, tried over 40 criminal trials in both D.C. Superior and Federal Courts, supervised more than 100 criminal trials, and briefed and argued criminal appeals. Deborah began her career at DOJ as a civil trial attorney in the Antitrust Division’s former Computers and Finance Section.Deborah received numerous awards while at DOJ, including five Special Achievement Awards, and the United States Attorney’s Star Award in the U.S. Attorney’s Office. During her time at the Criminal Division, Ms. Connor twice received the Assistant Attorney General’s Exceptional Service Award and the Assistant Attorney General’s Award for Distinguished Service. In 2021, Deborah was named one of Global Investigations Review’s (GIR) Top 100 Women in Investigations.Prior to joining DOJ, Deborah was a litigation associate at a large D.C.-based law firm, and before entering the practice of law, she joined a large Chicago-based commercial bank, where she served as a relationship manager for U.S. subsidiaries of multinational corporations.Deborah is a frequent speaker on AML and financial crimes enforcement. She has participated as a keynote speaker or panelist at conferences such as the American Bar Association’s (ABA) National Institute on White Collar Crime, ABA’s Financial Crimes Enforcement Conference, the Association of Certified Anti-Money Laundering Specialists’ (ACAMS) Annual AML & Anti-Financial Crime Conference, the Practising Law Institute, and the American Gaming Association.Deborah received her J.D. cum laude from Georgetown University Law Center, where she served on the Georgetown Law Journal as a notes editor. She received her B.A. from Miami University of Ohio.<h4>Representative Experience</h4><ul><li>Supervised the investigation and resolution of a matter involving a global financial institution and its European subsidiary related to fraud on financial investors. The matter resulted in a deferred prosecution agreement with the parent and a guilty plea with a subsidiary, guilty pleas of three employees, financial penalties, fines, and disgorgement.</li><li>Supervised the investigation and resolution of a matter involving a global financial institution and a foreign subsidiary in connection with bond deal underwriting. The matter resulted in a deferred prosecution agreement, a guilty plea for a subsidiary, financial penalties, and the conviction of two former high-level employees.</li><li>Supervised the investigation and resolution of a matter involving a foreign sovereign wealth fund, as part of the misappropriation of over $4.5 billion from the fund. The matter resulted in seizures of over $1.7 billion in assets as part of a civil forfeiture recovery.</li><li>Supervised the investigation and resolution of a matter involving a foreign financial institution related to a money laundering conspiracy in connection with a bribery scheme. The matter resulted in a deferred prosecution agreement, financial penalties, forfeiture, and the guilty pleas of two employees.</li><li>Supervised the investigation and resolution of a matter involving a foreign financial institution related to the processing of transactions in violation of U.S. sanctions. The matter resulted in a parent-level guilty plea and a non-prosecution agreement with a subsidiary, in addition to forfeiture.</li></ul>

Deborah Connor

Partner

Marc-Alain’s practice focuses on advising and counseling domestic and foreign financial institutions on a variety of bank regulatory, Bank Secrecy Act/anti-money laundering (BSA/AML), countering the financing of terrorism (CFT), and transactional matters. Marc-Alain has significant experience representing global financial institutions in criminal and regulatory investigations and enforcement actions as well as addressing weaknesses and shortcomings in their BSA/AML compliance frameworks. He also advises clients on all AML-related issues in connection with ESG, M&A, strategic investments and private equity funds, embedded finance, blockchain and digital assets, and other corporate transactions. Marc-Alain is adept at assisting clients to build ground up BSA/AML policies and procedures, and he works closely with banks and fintechs to navigate BSA/AML considerations related to Banking-as-a-Service (BaaS) and other partnership arrangements.Further, Marc-Alain has significant experience in advising and counseling U.S. and international bank holding companies, banks, and other financial institutions on a variety of bank regulatory and transactional matters, including matters relating to:<ul><li>The Bank Holding Company Act</li><li>Regulation K and Y</li><li>The Bank Merger Act</li><li>The Dodd–Frank Act (with regard to the Volcker Rule, Living Wills, and Enhanced Prudential Standards, among others)</li><li>Applications to federal and state banking regulators for expansion of activities</li><li>Internal restructuring</li><li>New products, sales, and acquisitions of U.S. banks</li></ul>Prior to joining Morrison Foerster, Marc-Alain was an associate with two prominent global United States law firms, and he practiced law in Switzerland for several years.Marc-Alain is a member of the board of the Swiss American Lawyers Association of Greater New York (SALA). He is fluent in German, English, French, and Spanish and has a basic knowledge of Italian. He is admitted to practice in New York and Switzerland.

Marc-Alain Galeazzi

Elizabeth (Liz) A. Aloi is Of Counsel in Morrison Foerster’s Investigations + White Collar Defense practice. A veteran federal prosecutor and seasoned trial lawyer, Liz has tried more than a dozen cases to verdict and spent nearly 20 years leading high-stakes criminal and civil enforcement matters at the U.S. Department of Justice.Drawing on experience across both the executive and legislative branches, Liz advises companies, boards, and executives navigating sensitive government enforcement actions and internal investigations involving financial crime, AML/Bank Secrecy Act obligations, sanctions, civil rights, and civil and criminal fraud.Before joining Morrison Foerster, Liz served as Chief of the Public Corruption and Civil Rights Unit at the U.S. Attorney’s Office for the District of Columbia. In that role, she supervised a broad enforcement docket, including civil rights offenses, procurement fraud, wire fraud, obstruction, campaign finance violations, insider trading, and other financial-crime matters. She managed complex investigations involving extensive electronic evidence, sensitive investigative techniques, and coordination with multiple federal law enforcement agencies.Earlier in her DOJ career, Liz served in various roles across the Criminal and Antitrust Divisions. As Chief of the Special Financial Investigations Unit in the Money Laundering and Asset Recovery Section, she led multijurisdictional matters involving money laundering, BSA/AML violations, kleptocracy, cryptocurrency, illicit finance, and asset forfeiture. She also served as a trial attorney in the Antitrust Division, where she prosecuted global price-fixing and procurement-fraud schemes, securing convictions of corporate and individual defendants in matters resulting in billions of dollars in criminal fines.Liz previously served as Senior Counsel to the U.S. Senate Judiciary Committee, where she supported the committee’s oversight and legislative work on criminal justice, corruption, money laundering, and sentencing policy.Liz earned her B.A. from Washington University in St. Louis and her J.D. from Columbia Law School.

Liz Aloi

Of Counsel

BSA/AML Advisory, Compliance, and Enforcement

Law360