Corruption & Money Laundering

Dwyer Law has significant experience in corruption and money‑laundering matters. Drawing on Jed’s government background investigating and prosecuting individuals and entities for corruption and violations of federal anti‑money‑laundering statutes, we bring real‑world insight to these complex and sensitive investigations.

That experience informs our strategic approach and allows us to navigate these matters with credibility, precision, and a clear understanding of how the government builds its cases.

Some of our experience includes:

Lead counsel in United States v. Boncy, a matter in which the United States Department of Justice charged Richard Boncy with conspiring to violate the FCPA, Travel Act violations, and a money laundering conspiracy. The evidence against Mr. Boncy included recording meetings, wiretap evidence, and significant documentary evidence. After a jury trial, the jury acquitted Mr. Boncy of all charges except for the least serious conspiracy charge. Post-trial, Jed was able to obtain a new trial for Mr. Boncy on the sole count of conviction. The United States immediately took an appeal, and Jed was able to get the new trial order affirmed on appeal in the First Circuit Court of Appeals. When the case returned to district court, after a series of motions and late discovery disclosures by the government, Jed convinced the government to dismiss the case. Mr. Boncy returned home, with no conviction.

Represented a Guatemalan national alleged to have engaged in corruption in connection with managing and overseeing a large cell phone provider and distributor in Central America. Through early proactive engagement with eth U.S. Department of Justice—focused on the weaknesses of the allegations—the DOJ choose to decline the case.

Currently representing a Central American businessman alleged to have engaged in corruption in Central America.

Represented a Venezuelan national alleged to have engaged in corruption in relation to Venezuelan oil contracts.

Provided FCPA legal advice, local and state anti-corruption counseling, and due diligence advice to multinational corporations in several industries, including financial services, health care, hospitality, cellular services, and technology.

Obtained an acquittal as lead counsel in a federal criminal trial where the defendant was charged with a multimillion-dollar money laundering conspiracy.

Persuaded the Department of Justice to decline charging an individual with money laundering charges. Jed’s representation of the client – which resulted in a declination – occurred after the client had previously signed a statement admitting the underlying conduct with prior counsel.

Represented a target of a money laundering investigation related to Venezuelan corruption, which resulted in no charges being filed against the client.

Conducted multiple risk assessments for non-financial institution business to determine potential money laundering risks posed by nature of client’s business. Thereafter, designed and drafted an anti-money laundering compliance program for the business that addressed the unique trade-based money laundering risks posed to the client.

Provided legal advice and counsel to various clients on compliance with the Foreign Corrupt Practices Act (FCPA), the Bank Secrecy Act (BSA), AML for non-financial institutions, and Office of Foreign Asset Control (OFAC) sanctions concerning the Foreign Narcotics Kingpin Designation This counsel has included, review and audits of existing FCPA programs; advice on revisions of FCPA compliance programs; review of proposed acquisitions for potential FCPA or OFAC sanction risk; advice on divestments or sales related to assets of OFAC sanctioned individuals; internal risk assessment for creation of FCPA and AML compliance programs; and BSA/AML advice for financial institutions.

These examples are offered only to show experience and not as a prediction of any potential results of a potential client’s matter. Each case is different and requires different approaches, that will and can, result in different results.