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 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 nonpublic 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 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).