Free Consultations & We're Available 24/7
WE'RE A BOUTIQUE LAW FIRM.
TRUST 50 YEARS OF EXPERIENCE.
WE SERVICE CLIENTS NATIONWIDE.
So your probably sitting in your office right now with a Civil Investigative Demand from DOJ about supposed bank fraud, money laundering, or Bank Secrecy Act violations and your absolutely losing your mind. Maybe suspicious transactions triggered it. Maybe a whistleblower reported your AML program failures. Or maybe your bank got swept up in there latest crackdown on financial crimes. Look, we get it. Your TERRIFIED. And you should be! Because TD Bank just paid $1.8 BILLION for BSA violations and executives are going to PRISON!
Let me explain exactly what your facing here. When DOJ’s Money Laundering and Asset Recovery Section (MLARS) Bank Integrity Unit issues a CID, there not playing around. This unit has imposed over $25 BILLION in penalties since 2010 and they’re hungry for more!
A bank fraud CID means the government thinks your institution facilitated money laundering, violated the Bank Secrecy Act, helped customers evade taxes, or participated in fraud schemes. There gonna dig through EVERYTHING: every suspicious activity report (or lack thereof), every currency transaction report, all your AML policies, customer due diligence files, and internal communications about compliance.
The really scary part? These investigations often involve multiple agencies simultaneously. DOJ coordinates with FinCEN, OCC, Federal Reserve, and FDIC. Your not just fighting one agency – your fighting the entire federal banking regulatory apparatus!
Hold onto your chair because the numbers will make you physically sick. Let’s look at recent cases that’ll keep you up all night:
TD Bank: $1.8 BILLION total penalties, criminal guilty plea, compliance monitor for years, and executives facing prison. U.S. Bancorp: $528 million criminal penalty plus $185 million civil penalty – over $700 million total!
But here’s what’s really terrifying – these are negotiated settlements! If you fight and lose, penalties can be DOUBLE or TRIPLE these amounts. Plus, individual executives face personal criminal liability. We’re talking 5-20 years in federal prison for bank fraud, money laundering conspiracy carries 20 years, and BSA violations can mean 5 years per count!
Your probably wondering “Why us? What did we do wrong?” Let me tell you the most common triggers that destroy banks:
Suspicious Activity Reports (SARs) are huge – both filing them and NOT filing them! File too many? Your admitting problems. File too few? Your hiding crimes. There’s no winning! FinCEN uses sophisticated analytics to identify outliers in SAR filing patterns.
Whistleblowers from inside your bank are devastating. That compliance officer you fired? That teller who quit? They can get massive rewards for reporting BSA violations! Customer complaints about transactions being blocked or accounts closed often trigger investigations. Even worse, criminal prosecutions of your customers automaticaly trigger reviews of your AML program!
The scope of bank fraud CIDs is absolutley staggering. There demanding everything related to your AML program, and I mean EVERYTHING:
Every policy and procedure document, all training materials and attendance records, board minutes discussing compliance, internal audit reports and findings, suspicious activity monitoring systems and alerts, customer identification and due diligence files, correspondent banking relationships, high-risk customer accounts, and all communications about compliance issues.
But here’s what’s really unfair – they want “all documents relating to” these topics. That’s impossibly vague! We’ve seen banks produce millions of pages and still get accused of withholding documents. Its designed to be a trap where your guilty no matter what!
YES! And it’s happening more frequently! The Bank Secrecy Act has criminal provisions that target individuals, not just institutions. Bank executives are personaly liable for “willful” violations!
Here’s what’s especialy terrifying – “willful” just means you should have known about the violations. You don’t need actual knowledge! If your the Chief Compliance Officer and the AML program failed, your going to prison. If your the CEO and you didn’t ensure adequate compliance, your going to prison. We’ve seen executives get 5-10 year sentences for violations they claim they didn’t know about!
TD Bank had five employees conspiring to launder $39 million. You think they’re getting slaps on the wrist? NO! There facing decades in federal prison. And these weren’t senior executives – they were branch-level employees! Imagine what happens to C-suite executives!
This is where things get REALLY scary. Money laundering isn’t just about drug cartels anymore. DOJ is expanding money laundering prosecutions to include any financial institution that processes suspicious transactions!
The definition of money laundering is so broad now that almost any BSA violation can become a money laundering charge. Failed to file a SAR? That’s concealing criminal proceeds! Didn’t have adequate KYC procedures? That’s facilitating money laundering! Processed transactions you should have flagged? Conspiracy to launder money!
Money laundering conspiracy carries 20 YEARS in federal prison. And here’s the kicker – each transaction is a seperate count. We had a bank that processed 100 suspicious wire transfers. That’s 100 counts of money laundering, which could mean 2,000 years in prison! Obviously no one gets that, but it gives prosecutors massive leverage to force guilty pleas!
Buckle up for YEARS of hell. Bank fraud investigations are notoriously long and complex. The typical timeline looks like this:
Initial CID and document production (3-6 months of frantic work), follow-up subpoenas and expanding scope (6-12 months), employee interviews and depositions (6-12 months), forensic review of transactions (12-24 months), settlement negotiations or indictments (6-12 months). Your looking at 3-5 years minimum!
During this entire time, your bank is paralyzed. Customers flee to competitors. Stock price crashes. Regulators impose restrictions. Key employees leave. Legal fees reach tens of millions. We’ve seen healthy banks become shells of themselves before investigations even conclude!
This is the billion-dollar question – literaly! Complete cooperation might reduce penalties but means admitting crimes. Fighting preserves defenses but guarantees maximum penalties if you lose. There’s no good option!
Here’s the harsh reality from recent cases: TD Bank cooperated fully and still got hit with $1.8 billion and criminal charges! U.S. Bancorp cooperated and paid $700+ million! Cooperation doesn’t mean mercy – it just means a slightly less crushing defeat!
But fighting is even riskier. Banks that contest BSA violations at trial face penalties 2-3 times higher than settlements. Plus, executives who fight get longer prison sentences. The government has unlimited resources and a 95% conviction rate in financial crime cases. Your David vs. Goliath, except Goliath has nuclear weapons!
Oh, this is another nightmare! Beyond criminal charges and fines, bank fraud investigations threaten your very existence as a financial institution. Regulators can revoke your charter, FDIC can terminate deposit insurance, Federal Reserve can force you to divest, and state regulators can pile on with there own actions.
Even if you survive criminaly and financialy, you’ll be under a compliance monitor for YEARS. These monitors basicaly run your bank, second-guess every decision, and cost millions annually. GAO reports show banks under monitors face severe operational restrictions that make normal banking nearly impossible!
ABSOLUTELY! Bank fraud investigations are contagious! If your bank processed transactions for other banks (correspondent banking), those banks are now under scrutiny. If you share ownership with other institutions, they’re all targets. If executives worked at other banks, those banks get investigated too!
We’ve seen single investigations expand to entire banking networks. One small bank’s BSA violations triggered investigations of 15 other institutions in there correspondent network. Its like a virus spreading through the financial system, destroying everything it touches!
Look, we’re not your typical white-collar defense firm that dabbles in banking cases. We specialize in defending financial institutions and executives against these devastating investigations. We know BSA requirements inside and out. We understand AML systems and there weaknesses. We speak the language of banking compliance fluently.
More importantly, we know how to negotiate with MLARS, FinCEN, and banking regulators simultaneously. We know which violations they’ll compromise on and which are non-negotiable. We can prevent individual executives from becoming scapegoats while protecting the institution. Most critically, we know how to keep civil investigations from becoming criminal prosecutions!
Other firms tell you to just cooperate and hope for mercy. That strategy got TD Bank a $1.8 billion penalty and criminal conviction! We fight strategically, challenging there interpretations, questioning there transaction analysis, and forcing them to prove willful violations. When the government sees we’re involved, they know they’re in for a real fight, not an easy victory!
Call us RIGHT NOW at 212-300-5196
Your bank’s survival depends on immediate action!
Free consultation – We’ve defended dozens of banks – Available 24/7!
Don’t wait another minute! Every hour you delay is another hour DOJ is building there case. There analyzing your transactions, interviewing your employees, coordinating with regulators. The walls are closing in and you need someone fighting back immediately!
Remember – bank fraud investigations destroy institutions in months, not years. Once criminal charges are filed, its usualy too late. Once regulators act, your finished. The time to fight is NOW, before they lock you into an unwinnable position. Your bank’s survival literaly depends on what you do in the next 24 hours. Call us immediately!
Very diligent, organized associates; got my case dismissed. Hard working attorneys who can put up with your anxiousness. I was accused of robbing a gemstone dealer. Definitely A law group that lays out all possible options and best alternative routes. Recommended for sure.
- ROBIN, GUN CHARGES ROBIN
NJ CRIMINAL DEFENSE ATTORNEYS