Anti-Money Laundering Regulation Comes to Non-traditional Financial Service Providers: Real Estate Title Insurance Companies and Investment Advisers

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Focus on the recent developments in anti-money laundering (AML) regulation as they relate to businesses that are not traditionally considered financial institutions.  Our informative new program will address a pilot “geographic targeting order” issued by the Financial Crimes Enforcement Network, the U.S. Treasury Bureau tasked with AML regulation. It is designed to collect information from persons involved in real estate closings concerning potential suspicious activity in transactions in New York and Florida.  Also up for discussion is a proposed FinCEN rule intended for investment advisers who have not previously been subject to AML regulation.

Educational Objectives:
• Explore anti-money laundering (AML) regulators’ recent focus on businesses that are not traditional financial institutions 
• Learn to identify the requirements of AML compliance, risk areas, and potential exposure for companies and individuals

Who would benefit most from attending this program?
Inside and outside counsel as well as compliance personnel in the fields of real estate and investment services.



Nicole Healy is a partner in the Redwood City office of Ropers Majeski Kohn & Bentley. Ms. Healy has represented companies and individuals in a wide range of industries in complex commercial disputes; shareholder class action and derivative litigation, including in matters involving mergers and acquisitions, and corporate governance and control; and matters involving intellectual property rights and trade secrets.

She has conducted, and has represented companies and their executives in, corporate internal investigations.  Ms. Healy has also represented companies and individuals in investigations by the Securities and Exchange Commission, U.S. Attorney's Offices, and other government agencies.

She has tried cases to judgment in state and federal courts, and to decision in private arbitration proceedings. She also serves as a mediator for the U.S. District Court for the Northern District of California.

Prior to entering private practice, Ms. Healy was a prosecutor for the U.S. Department of Justice, in the Fraud Section, Criminal Division where she focused on violations of the U.S. Foreign Corrupt Practices Act ("FCPA"), defense procurement fraud, and international criminal matters.  She is a frequent speaker regarding the FCPA and money laundering.

Ms. Healy is the author of the Anti-Money Laundering Deskbook, a Practical Guide to Law and Compliance (Practising Law Institute, July 2014).  She is also the co-chair of the ABA International Section’s Anti-Money Laundering Committee.

Ms. Healy holds a J.D. and is a graduate of UCLA Law School.  She is a member of the State Bar of California. 


Adam Safwat is counsel in Weil’s White Collar Defense & Investigations practice and is resident in the firm’s Washington, DC office. His practice focuses on white collar criminal defense, regulatory enforcement matters, and internal investigations.

Mr. Safwat previously served as a Deputy Chief of the Fraud Section of the U.S. Department of Justice’s Criminal Division from 2012 to 2014. He also served in the Fraud Section as an Assistant Chief from 2008 to 2012 and as a Trial Attorney and Senior Trial Attorney from 2006 to 2008.

During his time at the Fraud Section, he worked on a number of significant Foreign Corrupt Practices Act investigations involving companies operating in the commodities, oil services, logistics, and defense industries and on several complex securities fraud investigations of individuals and entities in the financial services industry.

In addition to his case work, Mr. Safwat worked on policy matters such as new criminal discovery initiatives within the Criminal Division.

Prior to joining the Fraud Section, Mr. Safwat spent four years as an Assistant U.S. Attorney in the U.S. Attorney's Office for the District of Delaware, where he conducted jury trials in general crimes cases and also concluded a number of successful white collar investigations in areas such as theft of trade secrets and tax fraud.

Earlier in his career, Mr. Safwat spent approximately six years in private practice and served as law clerk to the Honorable Walter K. Stapleton of the U.S. Court of Appeals for the Third Circuit in Philadelphia.

Mr. Safwat received his J.D. and LL.M. in International Law from the Duke University School of Law, where he graduated Order of the Coif and served as a notes editor of the Duke Law Review. He received his B.A. in Political Science from the University of California, where he graduated with high honors.

In 2015, Legal 500 recognized Mr. Safwat as a recommended lawyer nationwide for White Collar Defense, while Global Investigations Review called him a “name to know” in its inaugural edition of the GIR 100.