Jeremy Kuester is a counsel in the Washington, DC office of White & Case LLP, as a member of the Global Financial Services Regulation practice. He has extensive experience with Bank Secrecy Act (BSA) regulations, legislation, compliance, and policy. His practice includes advising banks and other financial services companies on the laws and regulations involving anti-money laundering and financial intelligence, including how they intersect with developments in financial technology (FinTech), regulatory technology (RegTech), and supervisory technology (SupTech). He also has an interest in assisting financial institutions who have been “de-risked” to re-obtain access to correspondent accounts by updating and enhancing their anti-financial crime compliance policies and controls.
Jeremy has authored numerous insightful publications related to the legislative and regulatory challenges faced by financial institutions. Notably, he is a key contributor to our Firm’s Coronavirus Financial Regulatory and Legislative Dashboard, which provides periodic updates and insights as the COVID-19 crisis and the response develop.
Before joining White & Case, Jeremy Kuester was the Deputy Associate Director for the Policy Division at the Financial Crimes Enforcement Network (FinCEN), a bureau of the Treasury Department that serves as the administrator and lead regulator of the Bank Secrecy Act (BSA). During his tenure there, he oversaw the publication of numerous anti-money laundering advisories to the financial sector, the promulgation of guidance on such areas as the May 2016 Customer Due Diligence Rule, and grants of exceptive relief from BSA regulations. He also drove efforts to be more responsive to how technological advancements impact the conduct of BSA/AML compliance. Jeremy also served as a Brookings Legislative Fellow in the Office of US Senator Jack Reed, where he covered issues involving the Bank Secrecy Act, corporate governance, and cybersecurity, among other issues.
In the private sector, Jeremy worked as an in-house compliance attorney with the retail, commercial, and investment banks of Merrill Lynch and subsequently joined the ethics team at Bank of America.
A US Retail and Commercial Bank
Advised a large US retail and commercial bank on interpreting and applying its reporting responsibilities under the BSA to the operations of third party service providers.
A Non-US Bank
Advised a prominent bank in Central Asia on the suitability of its anti-financial crime compliance policies and procedures to meet the expectations of correspondent banks in the United States.
A Non-US Central Bank
Through the Financial Services Volunteer Corps, provided technical assistance to the Central Bank and Financial Intelligence Unit of Central Asian country on improving its anti-money laundering and financial intelligence capabilities to come in line with the international standards set by the Financial Action Task Force (FATF).
An International Diamond Wholesaler
Advised an international diamond wholesaler on updating its anti-money laundering policies and procedures to comply with international expectations for dealers in precious metals, stones, and jewels.
A Globally-Active International Bank
Advised a globally-active international bank on interpreting and complying with the U.S. Financial Crimes Enforcement Network’s Rules on customer due diligence and beneficial ownership.
"Following the Money to Combat Human Trafficking," 2020 Virtual Annual Meeting – American Bar Association’s International Law Section, June 2020
"Future State of Digital Banking: Implications for Financial Crime Threat Post COVID-19," Refinitiv, June 2020
"Implementing Effective BSA/AML Compliance, Terrorist Financing Prevention and Fraud Deterrence Programs," 20th Prepaid Card Compliance Event, American Conference Institute, January 2020
"Rolling the Dice: Casinos, Money Laundering and the Fifth Pillar," Association of Certified Financial Crime Specialists, Webinar, September 2019
"A First Anniversary: Assessing the CDD Final Rule’s First Year," Association of Certified Anti-Money Launder Specialists, Webinar, June 2019
"Customer Due Diligence: Post-Implementation Review," Institute of International Bankers Annual Anti-Money Laundering Seminar, May 2019
"Hot Topics and Federal Updates," American Gaming Association AML Summit, February 2019
"Payroll Protection Program and the Bank Secrecy Act: Balancing Aid to Small Businesses with Financial Crime Risks," Bloomberg Law, April 2020
"Money laundering – The reality of Ozark: If Marty Byrde can do it, why can't I?" Thomsons Reuters Regulatory Intelligence, April 2020
"Unseen Stories: How financial institutions are helping in the fight against modern slavery," International Banker, February 24, 2020
"White & Case Discusses Cannabis Banking Bill’s Implications for Financial Services," Columbia Law School’s CLS Blue Sky Blog, October 2019
"Structured Finance Special Purpose Vehicles and FinCEN’s CDD Rule," The Review of Securities & Commodities Regulation, October 2019
"Correspondent Risk: Financial Crimes and Correspondent Banking," The Banking Law Journal, October 2019
"AML Information Sharing in a Technology-Enabled and Privacy-Conscious World," New York University School of Law Compliance & Enforcement Blog, February 2019.