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Anti-Money Launderting (AML)
Safeguarding Financial Integrity Through Legal Precision and Global Compliance Strategy
Financial crime poses one of the greatest threats to the integrity of global markets. To combat money laundering and terrorist financing, regulators around the world have established comprehensive Anti-Money Laundering (AML) frameworks that impose strict obligations on financial institutions, fintech companies, cryptocurrency exchanges, and professional service firms.
At SJKP LLP, our Anti-Money Laundering (AML) Practice helps clients navigate this increasingly complex regulatory environment with clarity, rigor, and foresight. We design and audit AML programs, advise on investigations, and represent clients before U.S. and international authorities—including the Financial Crimes Enforcement Network (FinCEN), Office of Foreign Assets Control (OFAC), and Department of Justice (DOJ).
Our team combines legal, regulatory, and operational expertise to deliver end-to-end compliance solutions that protect our clients’ reputation, minimize risk, and ensure full alignment with global AML standards.
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1. Understanding AML Frameworks and Regulatory Expectations
Navigating the Laws that Define Financial Transparency
Modern AML regulation is built on a network of laws and international standards designed to prevent illicit financial flows. Understanding the interaction among these frameworks is essential for maintaining compliant operations.
The U.S. AML Legal Landscape
U.S. AML obligations stem primarily from the Bank Secrecy Act (BSA) and the USA PATRIOT Act, which require financial institutions and money service businesses to detect and report suspicious activity.
Regulatory agencies include:
- - FinCEN: Oversees AML program requirements and suspicious activity reporting.
- OFAC: Enforces economic sanctions and prohibits transactions with restricted parties.
- Federal Reserve, OCC, and FDIC: Supervise banks’ AML compliance.
- SEC and CFTC: Regulate AML programs for broker-dealers, investment firms, and commodities traders.
SJKP LLP advises clients on how these rules intersect, ensuring that every aspect of their operations—from onboarding to reporting—meets federal expectations.
Global AML Standards
Beyond U.S. borders, the Financial Action Task Force (FATF) sets global AML and counter-terrorist financing (CFT) benchmarks. Many countries also maintain their own frameworks, requiring multinational organizations to comply with overlapping obligations.
We help clients harmonize AML practices across jurisdictions, minimizing duplication while maintaining global consistency.
Who Must Comply
AML rules extend far beyond banks. Obligated entities now include:
- - Fintech and payment platforms
- Cryptocurrency exchanges and custodians
- Securities and investment firms
- Real estate companies
- Law, accounting, and trust service providers
SJKP LLP tailors compliance solutions to each client’s risk profile and operational model.
2. Building and Maintaining Effective AML Programs
Designing Systems That Detect, Deter, and Defend
A robust AML program is more than regulatory paperwork—it’s a risk management framework that protects businesses from criminal exposure and reputational harm.
Core Components of an AML Program
Under FinCEN guidelines, every AML program must include:
- - Internal controls – Policies and procedures to identify and mitigate risk.
- Designation of a compliance officer – A qualified individual responsible for oversight.
- Ongoing training – Employee education tailored to risk exposure.
- Independent testing – Regular audits to assess program effectiveness.
- Customer due diligence (CDD) – Know Your Customer (KYC) procedures and enhanced due diligence for high-risk clients.
SJKP LLP helps clients implement and refine these components to meet or exceed regulatory standards.
Know Your Customer (KYC) and Customer Due Diligence (CDD)
KYC and CDD form the backbone of AML compliance. We assist clients in designing procedures for:
- - Customer identity verification
- Beneficial ownership identification
- Risk-based client segmentation
- Ongoing monitoring and transaction review
Our attorneys ensure that KYC frameworks comply with both U.S. BSA rules and international FATF recommendations.
AML Technology and Data Governance
Digital transformation has revolutionized AML monitoring. However, the use of AI and blockchain analytics introduces new privacy and data security challenges.
SJKP LLP guides clients through implementing AML technology—balancing regulatory compliance, cybersecurity, and data governance to maintain effective yet lawful monitoring systems.
3. Sanctions Compliance and International Enforcement
Managing Risk in a Globalized Economy
Sanctions violations are among the most severe AML-related offenses. Companies must ensure that no transactions involve restricted entities, sanctioned jurisdictions, or prohibited activities.
OFAC and Sanctions Screening
Our attorneys design sanctions compliance programs that incorporate OFAC’s Specially Designated Nationals (SDN) list, regional embargoes, and sectoral sanctions.
We advise clients on implementing real-time screening systems, managing false positives, and responding to enforcement inquiries.
Cross-Border Transactions and Correspondent Banking
International financial transactions raise heightened AML scrutiny. We help clients manage correspondent banking relationships, document due diligence, and comply with foreign reporting regimes—including the EU’s AML directives and UK’s Sanctions and Money Laundering Act.
Responding to Sanctions Investigations
SJKP LLP represents clients in civil and criminal investigations involving sanctions breaches or money laundering allegations. Our experience includes negotiating settlements, voluntary disclosures, and deferred prosecution agreements with U.S. authorities.
4. AML Audits, Investigations, and Enforcement Defense
Protecting Businesses When Regulatory Scrutiny Intensifies
Even the best AML programs can attract scrutiny. Whether through periodic audits or enforcement actions, regulators expect full transparency and accountability.
Regulatory Examinations and Audits
We prepare clients for regulatory examinations by reviewing policies, conducting mock audits, and identifying vulnerabilities before regulators do.
Our attorneys engage with examiners from FinCEN, OFAC, and state banking departments to ensure findings are managed effectively.
Internal Investigations and Remediation
When internal red flags arise—such as suspicious transactions, employee misconduct, or compliance failures—SJKP LLP conducts discreet investigations.
We identify root causes, develop remediation plans, and prepare documentation that demonstrates good-faith corrective action.
Defending Against AML Enforcement Actions
Enforcement can result in heavy fines, criminal liability, or reputational damage. Our defense team has experience negotiating settlements, reducing penalties, and, where necessary, litigating enforcement actions in federal court.
We help clients manage parallel investigations involving the SEC, DOJ, or foreign regulators, coordinating global defense strategies that align with business objectives.
5. AML in Emerging Financial Technologies
Integrating Compliance into Digital Innovation
The rise of cryptocurrency, DeFi (decentralized finance), and digital banking has reshaped AML risk profiles. Regulators now demand that technology-driven financial services meet the same standards as traditional institutions.
AML Compliance for Crypto and Fintech Firms
We advise digital asset exchanges, wallet providers, and payment apps on AML registration, monitoring, and reporting obligations.
Our attorneys design compliance architectures that integrate blockchain analytics, ensuring traceability while preserving innovation.
Virtual Asset Service Providers (VASPs) and FATF Guidance
Under FATF’s definition, VASPs must comply with global AML and CFT standards. SJKP LLP helps clients implement travel rule compliance, cross-border reporting, and counterparty verification processes that meet international expectations.
Balancing Innovation and Regulation
Our philosophy is simple: compliance should enable innovation, not stifle it. We help clients create flexible AML frameworks that evolve with technology and regulatory guidance, positioning them for sustainable growth.
6. Why Choose SJKP LLP for AML Compliance
Comprehensive Defense. Proactive Strategy. Global Perspective.
At SJKP LLP, we view AML compliance not as a cost of doing business, but as a foundation for long-term trust and integrity.
Our multidisciplinary team includes former regulators, compliance officers, and trial attorneys who understand both the letter and the spirit of AML law.
We provide clients with practical, forward-thinking counsel—helping them anticipate regulatory shifts, prevent violations, and respond effectively when scrutiny arises.
From designing compliance frameworks to defending against enforcement, SJKP LLP delivers confidence in the face of complexity.
We don’t just help clients meet AML requirements—we help them lead in compliance excellence across the global financial system.
The information provided in this article is for general informational purposes only and does not constitute legal advice. Reading or relying on the contents of this article does not create an attorney-client relationship with our firm. For advice regarding your specific situation, please consult a qualified attorney licensed in your jurisdiction.
Certain informational content on this website may utilize technology-assisted drafting tools and is subject to attorney review.
