Benjamin W. Hutten is an Associate in the New York office of Buckley Sandler LLP. He provides regulatory and compliance counsel, as well as internal investigative and enforcement defense services, to foreign and domestic financial institutions regarding federal and state financial services issues.
Mr. Hutten has a deep understanding of anti-money laundering (AML) and sanctions regulations and enforcement. In addition to his client work, he has participated in numerous financial industry group regulatory initiatives related to sanctions and AML issues, including The Clearing House Guiding Principles for Anti-Money Laundering Policies and Procedures in Correspondent Banking, initiatives to address “de-risking,” and initiatives related to information sharing.
His experience includes:
- Representing numerous financial institutions in cross-border, multiagency criminal and regulatory investigations into past compliance with U.S. sanctions
- Drafting a global U.S. sanctions compliance program for a global systemically important banking organization
- Advising foreign and domestic financial institutions in public and non-public regulatory examinations and enforcement actions by the Federal Reserve, Office of the Comptroller of the Currency (OCC), and New York State Department of Financial Services (NYDFS)
- Assisting financial institutions to conduct AML and sanctions-related internal investigations and look-back reviews
- Advising financial institutions in the areas of sanctions and anti-money laundering, such as assessing proposed transactions for sanctions compliance, improving compliance programs to meet regulatory expectations, advising on money services business licensing requirements and preparing voluntary self-disclosures to the Office of Foreign Assets Control (OFAC)
Prior to joining Buckley Sandler Mr. Hutten was an Associate at Sullivan & Cromwell LLP. He received his J.D. from New York Law School (summa cum laude) and his B.A. from Vassar College (Phi Beta Kappa).
The past year has seen several important changes in the sanctions landscape. Keeping up with these developments is a financial crimes compliance imperative. We discussed recent developments in the financial crimes arena including: Easing of Cuba and Iran sanctions Escalation of North Korea...Webcast
Benjamin W. Hutten Quoted in ACAMS Moneylaundering.com Article, “US Shipping Ban Against North Korea Draws Concern from Banks: Sources”
Benjamin Hutten was quoted on December 12, 2017 in an ACAMS Moneylaundering.com article, “US Shipping Ban Against North Korea Draws Concern from Banks: Sources,” which discussed the scrutiny banks will receive following an executive order in relation to North Korea sanctions. The article stated, “...In The News
Benjamin W. Hutten Quoted in ACAMSMoneyLaundering.com Article, “US Banks Frequently Fail to Identify All Correspondent Clients: Regulator”
Benjamin W. Hutten was quoted on April 21, 2017 in an article on ACAMSMoneyLaundering.com regarding “US Banks Frequently Fail to Identify All Correspondent Clients: Regulator.” The article discussed the struggle by U.S. financial institutions to properly identify and monitor foreign banks and...In The News
Benjamin W. Hutten Quoted in Association of Certified Financial Crime Specialists Article, "In Wake of OFAC Action Against Canadian Payment Processor, Bank to Review Customers, Policies"
Benjamin W. Hutten was quoted on September 29, 2016 in an Association of Certified Financial Crime Specialists article, "In Wake of OFAC Action Against Canadian Payment Processor, Bank to Review Customers, Policies." According to the article, during the week of September 19, the U.S. government “...In The News
"BSA/AML Compliance and Enforcement" By Daniel P. Stipano, Ellen M. Warwick, Brendan Clegg, and Benjamin W. Hutten (ABA Bank Compliance)
After nine months in office, it seems unlikely that the administration’s efforts to change the existing financial industry regulatory regime will affect enforcement of the Bank Secrecy Act (BSA) and its implementing regulations. To the contrary—it appears that law enforcement and national security...Articles
Daniel P. Stipano, Ellen M. Warwick, and Benjamin W. Hutten Authored The Review of Banking & Financial Services Article, "FinCEN's Customer Due Diligence and Beneficial Ownership Rule"
On May 11, 2016, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a long-awaited final rule, Customer Due Diligence Requirements for Financial Institutions (the “Final Rule”). The Final Rule, which impacts anti-money laundering (“AML”)-related obligations...Articles
OCC Comptroller Thomas J. Curry announced Wednesday during a speech at the Association of Certified Anti-Money Laundering Specialists (ACAMS) conference that the OCC is developing guidance around “de-risking” in foreign correspondent banking relationships. Following the joint fact sheet published...Articles
- J.D., New York Law School
- B.A., Vassar College
- New York