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Profile Picture

Amy G. Rudnick

Amy
Rudnick

Partner

CONTACT INFO

arudnick@gibsondunn.com

TEL:+1 202.955.8599

FAX:+1 202.530.9588

Washington, D.C.

1050 Connecticut Avenue, N.W., Washington, DC 20036-5306 USA

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PRACTICE

Financial Institutions Anti-Corruption & FCPA Anti-Money Laundering Securities Enforcement White Collar Defense and Investigations

BIOGRAPHY

Amy G. Rudnick, a retired former partner in the Washington, D.C. office of Gibson, Dunn & Crutcher LLP, joined the firm in 1995 and retired in 2016. Ms. Rudnick co-chaired the firm’s Financial Institutions Practice Group and was a member of the White Collar Defense and Investigations Practice Group.

Ms. Rudnick’s practice focused primarily on representing financial institutions in connection with criminal, civil, and regulatory enforcement actions and in responding to regulatory examinations involving compliance with anti-money laundering (“AML”) laws and regulations, including the Bank Secrecy Act, as amended by the USA PATRIOT Act (“BSA”).  She assisted financial institution holding companies, domestic and multinational banks, securities broker-dealers, investment companies, insurance companies, finance companies, money services businesses, casinos, other financial services businesses, and multinational corporations in developing, enhancing and implementing risk-based AML compliance programs, customer due diligence and enhanced due diligence policies and procedures, and procedures for identifying and reporting suspicious activity.  For ten years, Ms. Rudnick was a member of the Treasury Department’s Bank Secrecy Act Advisory Group.

Ms. Rudnick also served as counsel to the independent consultants in two of the residential mortgage foreclosure reviews that were undertaken pursuant to consent orders entered into by the servicers with the Office of the Comptroller of the Currency and the Board of Governors of the Federal Reserve System.

Prior to joining the firm, Ms. Rudnick was the Director of the U.S. Department of the Treasury’s Office of Financial Enforcement, the predecessor to the Financial Crimes Enforcement Network.  While at the Treasury Department, Ms. Rudnick was responsible for proposing BSA and AML legislation, issuing BSA regulations and interpretations, investigating and assessing civil money penalties, and coordinating BSA compliance with the Treasury Department and other bank supervisory agencies, the Securities and Exchange Commission, the Internal Revenue Service, and the federal law enforcement authorities with BSA/AML authority.  Her international efforts included participation in the G-7 Financial Action Task Force on Money Laundering and the negotiation of law enforcement cooperation agreements with foreign governments.

Previously, Ms. Rudnick was a Trial Attorney in the U.S. Department of Justice’s Criminal Division, Narcotic and Dangerous Drug Section, where she investigated and prosecuted drug trafficking and money laundering cases, and a law clerk to the Honorable Ellen Bree Burns, United States District Court Judge, District of Connecticut.

Ms. Rudnick has been ranked nationally as a leading lawyer for Financial Services Regulation in Chambers USA: America’s Leading Lawyers for Business for seven consecutive years (2010-2016).  In November 2016, she was awarded a Lifetime Leadership and Service Award by the American Bankers Association and the American Bar Association for her work in the area of anti-money laundering compliance.

Ms. Rudnick received a Bachelor of Arts degree from Stanford University, and she graduated with honors from the George Washington University Law School.

EDUCATION

The George Washington University - 1980 Juris Doctor

Stanford University - 1976 Bachelor of Arts

ADMISSIONS

District of Columbia Bar

RECENT PUBLICATIONS

Client Alert - August 1, 2016 | FinCEN Expands Temporary Reporting Requirements on Title Insurance Companies for All Cash Luxury Real Estate Transactions to Six Major U.S. Areas
Client Alert - July 6, 2016 | Beneficial Ownership and Customer Due Diligence:  Perspectives on the Increased Compliance Risk Associated with the Implementation of FinCEN’s Final Rule
Client Alert - February 11, 2016 | Do Not Pass Go, Do Not Collect $200: FinCEN Imposes Temporary Reporting Requirements on Title Insurance Companies for All Cash Luxury Real Estate Transactions in Manhattan and Miami
Client Alert - December 7, 2015 | Personal Liability for Senior Compliance Officers Under New York’s Proposed Anti-Money Laundering and Anti-Terrorism Regulation
Client Alert - September 1, 2015 | FinCEN Proposes Regulations That Would Require AML Programs and Suspicious Activity Reporting for SEC Registered Investment Advisers
Client Alert - June 5, 2013 | The Consumer Financial Protection Bureau: Its Foundation, Authorities, and First Year of Enforcement
Client Alert - April 11, 2012 | Department of the Treasury Issues Bank Secrecy Act Advance Notice of Proposed Rulemaking Relating to Customer Due Diligence Requirements for Financial Institutions
Client Alert - November 1, 2011 | FinCEN Issues Final Rule Implementing New CISADA Regulations to Require U.S. Banks to Seek Information from Foreign Correspondent Banks Regarding Financial Ties to Iran
Client Alert - February 17, 2011 | U.S. SEC Extends the Customer Identification Program No-Action Letter for Broker-Dealers and Changes the Terms
Client Alert - January 26, 2011 | U.S. Financial Crimes Enforcement Network Issues Guidance Regarding Recent Events in Tunisia
Client Alert - October 12, 2010 | FinCEN Proposes Reporting of Cross-Border Electronic Transmittals of Funds
Client Alert - July 28, 2010 | Iran Sanctions Legislation: New Controls and Penalties for U.S. Financial Institutions
Client Alert - August 7, 2009 | IRS Further Extends FBAR Filing Deadline to June 30, 2010 for Certain U.S. Persons
Client Alert - June 29, 2009 | IRS Confirms That Investors in Foreign Hedge Funds and Private Equity Funds Must File Reports of Foreign Financial Accounts; Filing Deadline Extended to 9/23/09 for Certain Taxpayers
Client Alert - January 30, 2009 | Senators Grassley and Levin Introduce Hedge Fund Transparency Act
Client Alert - January 20, 2009 | Joint Justice Department and Manhattan District Attorney Investigation Results in Record $350 Million Payment for OFAC Violations
Client Alert - December 23, 2008 | New Bank Secrecy Act/Anti-Money Laundering Examination Manual for Money Services Businesses
Client Alert - December 9, 2008 | OFAC Issues Guidance to the Securities and Futures Industry
Client Alert - October 3, 2008 | Casinos Continue to Be Vulnerable to Money Laundering
Article - December 17, 2007 | Internet Gambling Rules Would Enlist Banks to Fight Uphill Battle
Client Alert - November 26, 2007 | Treasury Issues New Bank Secrecy Act Guidance for Casinos and Card Clubs
Client Alert - March 15, 2007 | U.S. Treasury Department Formally Severs Ties Between U.S. Financial Institutions and Banco Delta Asia
Client Alert - September 11, 2006 | 2006 Bank Secrecy Act/Anti-Money Laundering Examination Manual Clarifies Elements of Effective OFAC Compliance Program for ACH Transactions
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