AnnaLou Tirol

Partner

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AnnaLou Tirol counsels clients on anti-money laundering (AML) and fintech regulatory, compliance, and enforcement issues, drawing on two decades of government experience, most recently as Deputy Director of the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN).

Few lawyers share AnnaLou’s deep familiarity with AML laws and regulations. As FinCEN’s Deputy Director, the bureau’s second highest official, AnnaLou oversaw FinCEN’s operations, programs, and policy, including legislative and regulatory matters, public-private partnerships with financial institutions and fintechs, and enforcement and compliance matters related to the Bank Secrecy Act (BSA). Following Congress’ January 2020 enactment of the Anti-Money Laundering Act of 2020, AnnaLou led FinCEN’s implementation of the most significant legislation to modernize the BSA since the USA PATRIOT Act, including the Corporate Transparency Act’s beneficial ownership requirements.

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Corporate & Government Experience

Government Experience

  • Deputy Director, Financial Crimes Enforcement Network, U.S. Department of the Treasury
  • Acting Chief, Public Integrity Section, Criminal Division, U.S. Department of Justice
  • Assistant U.S. Attorney, U.S. Attorney’s Office, Southern District of California
  • Resident Legal Advisor, Office of Overseas Prosecutorial Development, Assistance and Training, Criminal Division, U.S. Department of Justice

Honors & Awards

  • U.S. Department of the Treasury Distinguished Service Award
  • U.S. Department of State’s Meritorious Honor Award
  • Assistant Attorney General’s Award for Distinguished Service
  • FinCEN Director’s Award for Excellence in Diversity and Inclusion

Admissions

Bar Admissions

  • California

*Admitted only in California; supervised by principals of the firm

Court Admissions

  • U.S. Tax Court, Southern District of California

Education

  • University of San Diego School of Law, J.D.
  • University of San Diego School of Law, LL.M.
  • University of Notre Dame, B.A.

Professional Activities

Speaker

  • "Compliance with the Corporate Transparency Act," USC Gould School of Law 2023 Tax Institute (January 25, 2023)
  • "The CTA Is Coming! What All Business Attorneys Need To Know About The Corporate Transparency Act," New York State Bar Association Webinar (December 8, 2022)
  • "WTF Is An NFT?: Navigating the Fast-Evolving Legal Landscape Surrounding Digital Assets," 2022 National Asian Pacific American Bar Association (NAPABA) Convention (November 4, 2022)

Clerkship

  • Honorable Ruben B. Brooks, U.S. Magistrate Judge, Southern District of California

Adjunct Professor

  • Georgetown University Law Center

Founding Member

  • Women’s Leadership Series, FinCEN

Alerts and Publications

Events

In the News

ACAMS moneylaundering.com: Reporting ‘Loophole’ Risks Undermining FinCEN’s New Database, Analysts Warn

January 20, 2023

ACAMS moneylaundering.com: Dozens of Whistleblowers Have Contacted FinCEN Since December: Sources

January 17, 2023

ACAMS moneylaundering.com: FinCEN Targets Human Smuggling Across Southwest Border

January 13, 2023

MoneyLaundering.com: Beneficial Owners and Sanctions Against Russia: Compliance in 2023

January 3, 2023

New York Law Journal: O’Melveny Adds Former SDNY Unit Chief to Growing White-Collar Practice

November 2, 2022

Reuters: O’Melveny Adds Manhattan Prosecutor, Continuing White Collar Buildout

November 1, 2022

ACAMS moneylaundering.com: For US Beneficial Ownership Database, Deepest Pitfalls May Lie Ahead

October 24, 2022

Today’s General Counsel: Corporate Transparency Act Announced

October 21, 2022

Bloomberg Law: US Money Laundering Team Is at Crossroads as New Leaders Named

October 12, 2022

The National Law Journal: Jones Day, O’Melveny, Venable and Katten Score Experienced Government Lawyers

September 26, 2022

POLITICO: POLITICO Playbook: Transitions

September 20, 2022

Law360: O’Melveny Adds Financial Crimes Deputy Chief As Partner

September 19, 2022

Reuters: Ex-FinCEN Official Joins O’Melveny as Law Firms Bulk Up White-Collar Groups

September 19, 2022

Bloomberg Law: O’Melveny Hires Ex-FinCEN Deputy Director AnnaLou Tirol in DC

September 19, 2022

Press Releases