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Amy Davine Kim’s practice focuses on U.S. regulation of financial services and international business with a focus on Bank Secrecy Act/anti-money laundering (BSA/AML) compliance and digital payments. As Counsel in the Washington, DC office of Buckley Sandler LLP, she advises financial institutions, money transmitters, payments innovators, and other clients on matters involving federal and state regulatory compliance, particularly those involving AML for banks and non-bank financial institutions regulated under the BSA, the Financial Crimes Enforcement Network (FinCEN), and the Office of Foreign Assets Control (OFAC).

Ms. Kim advises banks on all aspects of BSA/AML compliance, including customer identification programs, customer due diligence, review of potentially suspicious activities, preparing for examinations, responding to matters identified during examinations, and other strategic considerations involved in implementing and maintaining a BSA/AML program. She has also counseled clients on navigating the constantly changing landscape of sanctions compliance, assisting financial institutions as well as U.S. and non-U.S. businesses in assessing compliance obligations and restrictions on commerce.

Ms. Kim has a particular focus on payments matters involving money services businesses (MSBs) and loan and finance companies, both in helping banks assess risks and risk mitigation when providing services to these customers, as well as advising payments innovators, MSBs, and loan and finance companies on their compliance obligations under the BSA and state money transmitter laws. Where state money transmitter licensing obligations are implicated, she assists companies in assessing licensing requirements and exemptions from licensing, outreach to regulators, maneuvering the licensing process, developing associated compliance programs, and conducting training.

Her experience includes:

  • Advising banks on matters of focus in examinations, including customer due diligence for high risk customers such as money services businesses and foreign correspondent bank relationships, and providing support and guidance to banks with respect to the development or enhancement to existing programs to meet regulatory expectations
  • Investigating transaction activity to develop voluntary self-disclosures to OFAC involving potential violations of U.S. sanctions. Recent voluntary disclosures have resulted in No Action or Cautionary letters
  • Advising several fintech companies on BSA/AML obligations, and in particular Customer Identification Program (CIP) requirements, in developing platforms for banks to onboard their customers to meet bank regulatory expectations
  • Developing strategic plans for mobile payments providers, loan and finance companies, and money services businesses such as money transmitters, prepaid access providers, and companies involved in virtual currency platforms with respect to BSA/AML and OFAC compliance programs and establishing and navigating relationships with state banking regulators
  • Reviewing multiple unique and sophisticated payments platforms (including those using bitcoin and blockchain technology) to advise on the best strategy for achieving money transmitter licensing compliance, and executing those strategies to obtain licenses or exemptions to licensing
  • Serving as money transmitter acquisition counsel on both international remitters and virtual currency companies, advising investors on obligations required of target money transmitter companies
  • Counseling foreign institutional investors and other clients on legal aspects of structuring and participating in investment funds that make corporate securities and real estate investments worldwide, including technical matters related to the partnership, corporate and limited liability company agreements that establish investment funds

Ms. Kim served on the Board of Governors of the Washington Foreign Law Society from 2002-2004, and was Chair of her prior law firm’s Women’s Forum from 2000-2003 and Co-chair of the Alternative Work Schedule Task Force. She received her J.D. from the University of Notre Dame and her B.A. from Pepperdine University (cum laude).

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