AnnaLou Tirol


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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.


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


Bar Admissions

  • California

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

Court Admissions

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


  • 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


  • "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)


  • 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


STEP LA: Getting your house In order before January 2024

三月 29, 2023

APABA DC: Advancing Rule of Law Abroad

三月 23, 2023

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

三月 9, 2023

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

二月 28, 2023

USC Gould School of Law 2023 Tax Institute

一月 23, 2023

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

十二月 8, 2022

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

十二月 8, 2022

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

十二月 7, 2022

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

十一月 4, 2022

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

十月 26, 2022

Alerts and Publications

In the News

ACAMS Reporting ‘Loophole’ Risks Undermining FinCEN’s New Database, Analysts Warn

一月 20, 2023

ACAMS Dozens of Whistleblowers Have Contacted FinCEN Since December: Sources

一月 17, 2023

ACAMS FinCEN Targets Human Smuggling Across Southwest Border

一月 13, 2023 Beneficial Owners and Sanctions Against Russia: Compliance in 2023

一月 3, 2023

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

十一月 2, 2022

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

十一月 1, 2022

ACAMS For US Beneficial Ownership Database, Deepest Pitfalls May Lie Ahead

十月 24, 2022

Today’s General Counsel: Corporate Transparency Act Announced

十月 21, 2022

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

十月 12, 2022

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

九月 26, 2022

POLITICO: POLITICO Playbook: Transitions

九月 20, 2022

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

九月 19, 2022

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

九月 19, 2022

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

九月 19, 2022

Press Releases