Skip to main content
Menu Icon Menu Icon


Benjamin W. Hutten is Counsel in the New York office of Buckley LLP. He advises foreign and domestic financial institutions and corporations on financial crimes compliance and enforcement issues, including sanctions administered by the Office of Foreign Assets Control (OFAC) and anti-money-laundering (AML). He also provides investigative and enforcement defense services regarding federal and state financial services issues.

Mr. Hutten has a deep understanding of sanctions and AML 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 BSA information sharing. Mr. Hutten also conducts international trainings in AML and sanctions issues for the Financial Services Volunteer Corps.

His experience includes:

  • Representing numerous foreign 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
  • Drafting AML and OFAC compliance programs for a host of entities, ranging from export-import businesses, fintechs, banks, money transmitters and lenders
  • Assisting multiple corporate and financial institution clients to respond to OFAC subpoenas and submit voluntary self-disclosures to OFAC related to apparent violations of OFAC requirements
  • Conducting AML and OFAC risk assessments for corporate and financial institution clients
  • Advising foreign and domestic financial institutions in public and nonpublic regulatory examinations and enforcement actions by OFAC, 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
  • Conducting AML and sanctions-related due diligence on a host of domestic and cross-border transactions, including corporate financings, mergers, acquisitions, joint ventures and syndicated lending
  • Advising financial institutions and corporates in the areas of bank regulation, 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 OFAC

Mr. Hutten has been recognized by Best Lawyers in America as "One to Watch" and by Super Lawyers as a "Rising Star." Prior to joining Buckley 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).

Webcasts & Speaking Engagements

In The News


Awards and Recognitions

Awards & Recognitions

  • Best Lawyers One to Watch 2022: Banking and Finance Law
  • Best Lawyers One to Watch 2021: Banking and Finance Law
  • Super Lawyers Rising Star 2018-2020: New York Metro: Banking