Benjamin W. Hutten

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

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

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).