Braddock Stevenson
Counsel
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Drawing on his extensive government experience, Braddock Stevenson advises financial institutions and fintech companies on anti-money laundering and Bank Secrecy Act (BSA) compliance to help them navigate investigations and enforcement matters (not yet admitted in the District of Columbia*).
Braddock is a member of O’Melveny’s Coronavirus Task Force, advising clients on their eligibility for and obligations under available federal finance programs. He counsels small to mid-size businesses on SBA lending, Federal Reserve credit facilities, and health and human services grants and state and local governments on federal block grants.
Braddock joined O’Melveny after more than a decade at the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), most recently serving as Deputy Associate Director of FinCEN’s Enforcement Division.
While at FinCEN, Braddock oversaw BSA compliance and enforcement for all US financial institutions including banks, virtual currency exchanges, broker-dealers, money transmitters, casinos, and jewelry dealers. Braddock led multiple investigations into a broad range of financial institutions and served as the lead negotiator in resolving BSA matters. His work included developing the Department of the Treasury’s BSA supervision strategy for all US financial institutions and advising both private sector and government officials on compliance matters. His responsibilities also included investigating and drafting USA PATRIOT ACT section 311 actions and representing FinCEN in intra-agency task forces. Braddock spent four years stationed in the New York High Intensity Financial Crimes Area advising law enforcement on money laundering investigations. Braddock worked extensively on developing BSA policy for traditional and emerging payment systems including SWIFT, ACH, Fedwire, CHIPs, mobile payments, prepaid cards, and virtual currency platforms.
Government Experience
- Deputy Associate Director, US Department of the Treasury’s Financial Crimes Enforcement Network
- Director of the Office of Compliance and Enforcement, US Department of the Treasury’s Financial Crimes Enforcement Network
- Section Chief of Depository Institutions, US Department of the Treasury’s Financial Crimes Enforcement Network
- Section Chief of Eastern Hemisphere & Office of Special Measures, US Department of the Treasury’s Financial Crimes Enforcement Network
- Enforcement Officer of Enforcement Division, US Department of the Treasury’s Financial Crimes Enforcement Network
- Regulatory Policy Specialist in the Office of Regulatory Policy, US Department of the Treasury - Financial Crimes Enforcement Network
Admissions
Bar Admissions
- New Jersey
- New York
*Admitted only in New Jersey and New York; supervised by principals of the firm.
Education
- Case Western Reserve University School of Law, J.D., 2007
- Pennsylvania State University, B.A., 2004
Professional Activities
Speaking Engagements and Publications
- “FinCEN’s Crackdown on Self-Hosted Wallets,” O’Melveny Webinar (December 2020)
- “Information Sharing: Best Practices and Future Developments,” ACAMS San Diego Baja Chapter November Virtual Event (November 2020)
- “BitMEX Indictment Warns of New Department of Justice Approach on AML Program Failures,” The Recorder (November 2020)
- “Exploration of Advantages and Disadvantages of Geographic Targeting Orders,” CWRU Law Financial Integrity Institute (August 18, 2020)
- “Pandemic predators – Covid-19 fraud schemes,” Fraud Intelligence (July 2020)
- “US$484 Billion in New Funds for CARES Act Small Business Loans and Health Care Programs,” O’Melveny Client Alert (April 2020)
- “SBA’s Paycheck Protection Program and Economic Injury Disaster Loan Program,” O’Melveny Client Alert (April 2020)
- “Door Opens to Non-Traditional SBA Lenders’ Participation in SBA’s Paycheck Protection Program,” O’Melveny Client Alert (April 2020)
- “Federal Reserve Announces Two Main Street Lending Programs as Part of Stimulus Efforts,” O’Melveny Client Alert (April 2020)
- “CARES Act Enforcement Risks,” O’Melveny Client Alert (April 2020)
- “CARES Act: Direct Loans to Non-Investment Grade Businesses and Federal Reserve Liquidity Facilities,” O’Melveny Client Alert (April 2020)
- “COVID-19: Unemployment Assistance for Gig Workers and Independent Contractors,” O’Melveny Client Alert (March 2020)
- “COVID-19: Stimulus to Provide Unprecedented Government Assistance to US Businesses,” O’Melveny Client Alert (March 2020)
- “Individual Liability: FinCEN Issues Personal Penalty to Former Chief Compliance Officer,” O’Melveny Client Alert (March 2020)
- “Heads Up: AML and Economic Sanctions Moves the Crypto Industry Should Watch for From Regulators in 2020,” O’Melveny Client Alert (February 2020)
- “Developments Regarding BSA/AML and OFAC Compliance,” Institute of International Bankers (October 2019)
- “Risk-Based and Effective: Developing Trends in BSA Monitoring,” Institute of Internal Auditors Financial Services Exchange (September 2019)
- “BSA/AML Enforcement Update,” FFIEC Advanced BSA/AML Examiner School (July 2019)
- Texas Bankers Association Annual AML/BSA Compliance Meeting (June 2018)
- “BSA/AML Hot Topics,” Montana Bankers Association Annual AML/BSA Compliance Meeting (June 2018)
- “How to Develop an Effective Compliance Program to Address Evolving Federal Regulation,” American Bar Association Business Law Section Fall Meeting (November 2016)
- “Supervisory Developments Regarding BSA/AML and OFAC Compliance,” Institute of International Bankers (October 2016)
- “You Sent Funds Where? How to Help Remittance Transfer and Mobile Payment Clients Fess Up When They Mess Up BSA and OFAC Compliance,” American Bar Association Business Law Section Spring Meeting (April 2013)
