Carol Van Cleef

Partner
Manatt, Phelps & Phillips, LLP

Carol Van Cleef is co‐chair ofthe Global Payments practice group and a member of the Financial Services andBanking practice. She represents financial services companies and other clientsin federal and state regulatory, compliance, and enforcement matters, includinganti‐moneylaundering and OFAC compliance, electronic payments, privacy, data security,federal deposit insurance, and other regulatory issues. She counsels bankingand trust organizations, credit unions, securities firms, insurance companies,finance companies and money service businesses among others. Ms. Van Cleef hassignificant experience working with all types of MSBs (including domestic andforeign money remitters, virtual currency, bill payment systems, check cashers,currency dealers/exchangers), third‐party payment processors, storedvalue and prepaid access programs, and other alternative payment systems onstate money transmitter licensing and related regulatory requirements, federalMSB registration, BSA/AML/OFAC compliance, privacy and information securityprograms. She has advised represented publicly traded companies and privateequity funds in purchasing and selling various types of financial services andfintech companies. Ms. Van Cleef also has worked closely with the managementand shareholders of money services businesses seeking new funding sources andconfronting bankruptcy. A Certified Anti‐Money Laundering Specialist, Ms.Van Cleef is a frequent speaker on AML compliance‐related issues and has served as amember of the Editorial Task Force of ACAMS Today. She has created a series ofhighly acclaimed AML compliance training programs sponsored by the Conferenceof State Bank Supervisors, including the Boot Camp for BSA/AML ComplianceProfessionals, the Mini‐Boot Camp for Developing PrepaidCard AML Compliance Programs, and an intermediate course, Officer Training forBSA/AML Professionals. These programs have been attended by regulators frommore than 45 states and representatives of domestic and foreign banks,securities firms, MSBs and other companies. She has developed a similar AMLCompliance Bootcamp for Digital Currencies, which has been attended by arepresentative group of companies across the digital currency communityincluding miners, exchangers, processors, software developers, ATM operatorsand others including bankers. Ms. Van Cleef regularly advises clients oncompliance with the USA Patriot Act, the Bank Secrecy Act, and Office ofForeign Assets Control regulations. She assists clients in developing,reviewing, and enhancing BSA, AML, and OFAC compliance programs. She also workswith clients in analyzing implementation of their automated BSA/AML compliancesolutions, addressing enforcement actions and preparing for regulatoryexaminations and independent compliance reviews.