Senior judgment for consequential decisions.
Michael Reed leads the firm’s CTF compliance work for banks, correspondent institutions and payment businesses. He is a former Treasury OFAC senior enforcement officer and combines legal analysis with an operating understanding of governance, transaction data, screening and remediation. His practice addresses the points where BSA/AML duties, sanctions controls and terrorism-financing risk overlap, including foreign correspondents, nested relationships, Section 311 special measures and Sections 314(a) and 314(b).
Michael starts with how value and responsibility move through the institution. He maps products, customers, geographies, correspondents, intermediaries, data sources and decision rights. The review then tests whether risk assessment, diligence, monitoring, screening, case investigation and reporting form a coherent system. Findings identify evidence, root cause, owner, dependency and closure criteria. He favors control language that investigators and operations teams can use, not policies that merely restate regulations.
A compliance program is defensible when an institution can show who owns a control, what data it uses, how exceptions move and how effectiveness is tested.
How Michael works
When an institution is already under review, Michael sequences immediate risk reduction and sustainable remediation. Temporary controls may include targeted manual review, counterparty restrictions, refreshed watchlists or focused lookbacks. Longer-term work may involve data lineage, scenario coverage, model governance, staffing, quality assurance and independent testing. He coordinates those changes with enforcement counsel so a remediation plan remains accurate, achievable and consistent with the institution’s legal position.
Every matter begins with a defined scope, conflicts clearance and an agreed communications protocol. The team identifies urgent deadlines, relevant agencies, custodians, systems and jurisdictions. Confirmed facts are separated from reasonable inferences and open questions. That distinction is maintained in board materials, government submissions and internal work product so the client can make decisions without confusing an investigative lead with a legal conclusion.
Michael works closely with the firm’s defense, compliance, sanctions and policy leads. This integrated approach is important because one fact may be viewed differently under the material-support statutes, the Bank Secrecy Act, OFAC authorities, a contractual risk standard or a foreign-law restriction. Workstreams are coordinated, while privilege, professional duties and local-law responsibilities remain clear.
Focus areas
- Enterprise and product-level terrorist-financing risk assessments
- Correspondent banking, payable-through accounts, nested relationships and Section 311 risk
- Section 314(a) response and qualifying Section 314(b) information-sharing governance
- Transaction monitoring, sanctions screening, SAR governance and escalation design
- Lookbacks, remediation plans, issue validation and board or regulator reporting
Representative experience
Representative experience includes urgent response to government process; privileged reviews of transactions, communications and control decisions; preparation of witnesses and decision-makers; and development of clear submissions for prosecutors, regulators, sanctions authorities, boards and counterparties. Client confidentiality is maintained throughout every engagement, and prior experience does not guarantee a future result.
A matter may begin when a client receives parallel questions from a financial institution and government authority. Michael would organize the request set, preserve the evidence, identify the governing legal standards and develop a sequenced response. Where technical analytics, foreign law or specialized accounting is required, he defines the question and integrates qualified experts or local counsel into the legal work plan.
A related assignment may begin when an institution discovers a control weakness while reviewing a terrorism-related alert. The immediate work is to understand the transaction and prevent avoidable harm; the longer work is to determine scope, root cause, reporting implications and sustainable remediation. Legal defense and compliance improvement are coordinated so the record is accurate and the organization can demonstrate what changed.
Education and professional background
Education: Columbia Law School, J.D.; Wharton School, M.B.A. Prior public service: Ten years as a Treasury OFAC Senior Enforcement Officer. Professional focus: CTF compliance, correspondent banking, sanctions controls and regulator-facing remediation.
For an engagement inquiry, use the firm’s central confidential intake page. Individual contact numbers are not published. Do not send classified information, suspicious activity reports, privileged files or sensitive identity documents before the firm confirms an engagement and provides transfer instructions.
