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Anti-Money Laundering Defense & Financial Compliance

ENTRUST US WITH YOUR CASE

Money Laundering Defense & Compliance

Understanding AML Enforcement Risks

While anti-money laundering procedures serve essential protective functions, they are frequently subject to misapplication and abuse, leaving legitimate businesses and individuals vulnerable to unfounded investigations.

Common AML Enforcement Issues

Anti-money-laundering overreach and abuse

Financial institutions routinely file suspicious transaction reports without sufficient justification, crippling legitimate businesses through unexplained account closures and asset freezes – actions that often trigger prosecutorial intervention based on questionable evidence. I explore these cascading consequences in my recent analysis of anti-money-laundering overreach:

A single report can set in motion an irreversible chain of events: accounts frozen without warning, assets rendered inaccessible, businesses unable to meet payroll or pay suppliers. No explanation is provided – banks cite regulatory obligations and security concerns—and no meaningful appeal process exists. These reports routinely land on prosecutors’ desks as evidence of potential criminal activity, triggering investigations that can destroy reputations and livelihoods long before any formal charges are filed. The system operates on a presumption of guilt, and the burden of proving innocence falls entirely on those who find themselves caught in its machinery.

Financial Crime: Victims and the Accused

We represent both sides of financial crime – those who have lost assets to fraud and those accused of facilitating it.

For victims of online fraud, cryptocurrency theft, and exchange security breaches, we pursue recovery across jurisdictions where digital assets complicate traditional enforcement. The anonymity that makes cryptocurrency attractive also makes it difficult to trace, but not impossible. We work with forensic specialists and international counsel to follow the trail where it leads.

For individuals and entities facing money laundering allegations, we provide defense rooted in understanding how legitimate business activity can be mischaracterized as criminal. These cases often originate from tax disputes that escalate into criminal investigations—allegations of CIT fraud, aggressive tax planning reclassified as evasion, transactions deemed suspicious because authorities misunderstand their commercial purpose.

We provide strategic counsel for individuals and organizations conducting business in higher-risk jurisdictions, including the United Arab Emirates, the Marshall Islands and other developing financial centers, ensuring compliance while preserving legitimate commercial interests.

The line between optimization and criminality is frequently drawn by prosecutors rather than by law. We defend that line.

Tax-Related Accusations

Cases involving alleged CIT fraud, or aggressive Personal Income Tax optimization strategies where money laundering charges are added to compound prosecutorial leverage.

Cryptocurrency Activities

Representation for digital asset traders, exchange operators, and blockchain professionals facing scrutiny from traditional financial institutions unfamiliar with emerging technologies.

International Business Structures

Defense for clients utilizing legitimate corporate arrangements including tax residency changes, and economic citizenship programs.

We also provide compliance support to obligated institutions developing comprehensive anti-money laundering procedures.

Our Services

Our practice encompasses the full spectrum of anti-money-laundering compliance—from the development of procedures to the implementation of ongoing obligations – for a notably diverse clientele. We advise cryptocurrency exchanges navigating the increasingly complex regulatory landscape, art galleries and auction houses managing high-value transactions, jewelers and mints handling precious metals and rare coins. Our clients include lawyers, legal counsels, and tax advisors who themselves face AML obligations, as well as—in what might be considered the more challenging corners of the cryptocurrency world—mixer services and entities dealing in NFT tokens.

Criminal Defense & Asset Protection

– Representation against unjustified asset freezing by banks, law enforcement agencies, or tax authorities

– Defense following account termination without legal basis

– Criminal representation for money laundering allegations

– Appeals and administrative proceedings

Compliance & Risk Management

– Comprehensive audits of AML/CFT policies and procedures for compliance with national and international regulations

– Development of anti-money laundering and terrorism financing procedures

– Regulatory implementation support and ongoing compliance monitoring

– Institutional risk assessments for money laundering and terrorism financing

Regulatory Support

– Ultimate Beneficial Owner (UBO) identification protocols and customer due diligence procedures

– Regulatory dispute resolution with supervisory authorities

– Professional AML/CFT training programs for compliance personnel

International Tax Expertise

The transformation of global financial architecture over the past decade represents nothing less than a revolution in transparency. What began as discrete Tax Information Exchange Agreements (TIEAs) between individual jurisdictions evolved rapidly into the Automatic Exchange of Information (AEOI)—a comprehensive system that stripped away the opacity upon which countless offshore structures had depended. This framework, which I explore in Nowhere to Hide: The Death of Financial Secrecy, fundamentally altered the calculus for international tax cooperation and, perhaps more significantly, reshaped the entire landscape of anti-money laundering enforcement.

The implications extend far beyond tax compliance. These mechanisms—TIEAs, AEOI, and the broader apparatus of international financial transparency—have become indispensable tools in combating money laundering, terrorist financing, and financial crime. Information that once remained siloed within individual jurisdictions now flows automatically across borders, creating an interconnected web of oversight that makes concealment exponentially more difficult. Beneficial owners who might once have hidden comfortably behind nominee directors and complex corporate structures now find themselves exposed by mandatory reporting requirements and cross-border data sharing.

For professionals navigating this environment, the message is unequivocal: international tax expertise and AML compliance have converged into a single, integrated discipline. One cannot effectively structure cross-border arrangements without understanding both the tax implications and the anti-money laundering framework. The complete legal framework for 2025 demands this holistic approach—where substance, transparency, and rigorous compliance replace the outdated strategies of opacity and regulatory arbitrage.

International Sanctions Expertise

Skarbiec Law Firm maintains specialized expertise in international sanctions, addressing the complex intersection of domestic, European Union, United Nations, and United States sanctions regimes. Economic and financial sanctions create compliance obligations extending beyond financial institutions to encompass all natural and legal persons operating within EU jurisdiction or conducting business with EU entities abroad.

This represents an exceptionally complex legal landscape requiring simultaneous consideration of multiple overlapping sanctions frameworks, including targeted measures against Russia, sanctions against North Korea, and sanctions against Venezuela. Our practice ensures comprehensive compliance while protecting legitimate business operations and individual rights against regulatory overreach.

Gambling online enforcement and compliance

The digital gambling industry operates in a legal twilight zone where geography matters less than ever, yet jurisdiction determines everything. As I examine in The House Always Wins: How Caribbean Islands Became the World’s Casino Regulators, a handful of small island nations have positioned themselves as the primary licensing authorities for global online gambling operations, creating a regulatory landscape that is simultaneously sophisticated and fragmented.

This arrangement generates enormous revenue for these jurisdictions while leaving players and operators navigating a complex web of sometimes conflicting requirements. When things go wrong—as they inevitably do in an industry built on risk—the question becomes one of recourse.

Whether you’re facing enforcement action for compliance failures or seeking to recover funds from operators who have violated licensing terms, the path forward requires understanding both the regulatory framework that legitimized these operations and the practical mechanisms for asserting rights against entities that may exist only as digital storefronts backed by offshore corporate structures.

Our practice addresses the complete spectrum of online gambling legal issues, from compliance counseling for licensed operators to aggressive recovery efforts against illegal casinos that have appropriated client funds. For details see the article How to Get Your Money Back from Illegal Online Casinos?