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 US 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
  • District of Columbia

Court Admissions

  • US 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

  • "Leveraging Blockchain, Investigations, and Enforcement Actions," ACAMS US Capital Chapter: Cryptocurrency Forum: Intersection of ML/CFT & Emerging Risks (April 19, 2023)
  • "Getting your house in order before January 2024," STEP (March 29, 2023)
  • "Advancing Rule of Law Abroad," Asian Pacific American Bar Association DC (March 23, 2023)
  • "Unpacking AML Reform: The US AMLA 2020, UK Economic Crime Bill and EU AML Package 2021," ACAMS (March 9, 2023)
  • "The Corporate Transparency Act - Part 2," New York State Bar Association (February 28, 2023)
  • "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 (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

Events

NYU SPS 82nd Institute on Federal Taxation: The Corporate Transparency Act—Dealing with the New World of Beneficial Ownership and Control Disclosure

10月 22, 2023

ACAMS US Capital Chapter: Cryptocurrency Forum: Intersection of ML/CFT & Emerging Risks

4月 19, 2023

STEP LA: Getting your house In order before January 2024

3月 29, 2023

APABA DC: Advancing Rule of Law Abroad

3月 23, 2023

What Companies – And Not Just Financial Institutions – Need to Know about the New Anti-Money Laundering Whistleblower Program

3月 14, 2023

Unpacking AML Reform: The US AMLA 2020, UK Economic Crime Bill and EU AML Package 2021

3月 9, 2023

New York State Bar Association: The Corporate Transparency Act – Part 2

2月 28, 2023

USC Gould School of Law 2023 Tax Institute

1月 23, 2023

Latest FTX Developments: Potential Regulatory Enforcement, Criminal Liability, and a Bankruptcy Update

12月 8, 2022

New York State Bar Association: The CTA Is Coming! What All Business Attorneys Need To Know About The Corporate Transparency Act

12月 8, 2022

The Corporate Transparency Act’s New Beneficial Ownership Information Reporting Rule: Getting Your House In Order Before January 2024

12月 7, 2022

NAPABA Convention: WTF Is An NFT?: Navigating the Fast-Evolving Legal Landscape Surrounding Digital Assets

11月 4, 2022

Learn from the Pros: Anti-Money Laundering Priorities for Digital Asset and Web3 Companies

10月 26, 2022

Press Releases

Alerts and Publications

Life of the (Third) Party: Regulators Call for Banks to Examine Fintech Risks in Final Guidance for Third-Party Relationships

6月 20, 2023

Hong Kong Launches New Virtual Asset Trading Platform Licensing Regime

6月 9, 2023

Hong Kong Court Rules that Cryptocurrencies are Property in Landmark Decision

5月 29, 2023

United States Further Expands Economic Sanctions and Export Controls Targeting Russia As War in Ukraine Continues

5月 22, 2023

Hong Kong SFC Consults on Proposals to Regulate Virtual Asset Trading Platforms

4月 4, 2023

Meet Your New Neighbor: FinCEN Is Moving In

3月 21, 2023

State Regulators Want a Piece of the FTX Fallout Too

2月 3, 2023

2022 Momentum Year in Review

1月 25, 2023

What Companies – And Not Just Financial Institutions – Need to Know about the New Anti-Money Laundering Whistleblower Program

1月 18, 2023

The Corporate Transparency Act Treasury’s New Beneficial Ownership Information Reporting Regime

12月 22, 2022

Takeaways from the Second (Proposed) Rule on Access: Who’s in the BOIs’ Club?

12月 22, 2022

Beneficial Ownership Information Reporting—Treasury’s New BOI Regime

10月 6, 2022

In the News

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

1月 20, 2023

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

1月 17, 2023

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

1月 13, 2023

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

1月 3, 2023

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

11月 2, 2022

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

11月 1, 2022

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

10月 24, 2022

Today’s General Counsel: Corporate Transparency Act Announced

10月 21, 2022

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

10月 12, 2022

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

9月 26, 2022

POLITICO: POLITICO Playbook: Transitions

9月 20, 2022

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

9月 19, 2022

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

9月 19, 2022

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

9月 19, 2022