Washington counsel for financial crime, national security and government enforcementEstablished 2002 · 1-202-9824-980
Portrait of Robert J. Hayes
Senior Attorney

Robert J. Hayes

Government Affairs, FARA & Terror Finance

EducationGeorgetown University Law Center, J.D.
Government serviceFormer Chief Counsel, Senate Banking and Senate Intelligence Committees — 20 years
ExperienceMore than three decades at the intersection of law, policy and oversight
Biography

Senior judgment for consequential decisions.

Robert J. Hayes advises on government enforcement, congressional oversight, FARA and national-security policy affecting terror finance. Before private practice, he spent two decades as chief counsel and senior counsel to Senate Banking and Intelligence Committee work. He understands how a request that begins as a policy inquiry can develop into testimony, compulsory process, public reporting or a referral, and why government-affairs communications must remain aligned with the legal defense.

Robert develops an agency and stakeholder map, establishes what each forum can request, and coordinates a common factual record. He prepares executives and subject-matter experts for briefings, interviews and testimony; reviews document productions and written responses; and tests public assertions against evidence. FARA analysis is integrated when foreign-principal relationships, political activity or public communications are implicated. Legislative or humanitarian-policy work is framed around operational facts rather than slogans.

Policy engagement is most credible when it is anchored to the same facts that will withstand a regulator, prosecutor or congressional record.

How Robert works

Robert’s role is not to turn a legal matter into a public campaign. He helps clients decide what must be said, what can responsibly be said and what should remain within privileged channels. When Congress, agencies, banks, donors or partners ask overlapping questions, he helps the team maintain consistency without using one audience’s language in a way that creates unintended consequences elsewhere. The result is advocacy that is accurate, restrained and connected to the client’s long-term 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.

Robert 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

  • Congressional inquiries, testimony preparation, document requests and committee briefings
  • Government affairs involving CTF policy, sanctions authorities and humanitarian access
  • FARA analysis for foreign-principal relationships and public-facing activity
  • Coordination of oversight responses with DOJ, OFAC, FinCEN and regulatory matters
  • Board, executive and stakeholder communications during high-profile investigations

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. Robert 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: Georgetown University Law Center, J.D. Prior public service: Two decades in senior counsel and chief counsel roles supporting Senate Banking and Senate Intelligence Committee work. Professional focus: Congressional oversight, FARA, government affairs and national-security policy.

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.

Senior lawyers working on a counter-terrorism finance matter
Practice in context

Legal analysis connected to how the facts move.

Financial, operational and government records are reviewed together, so the advice reflects both the law and the client’s real decision environment.

Explore the related practice, review the firm’s CTF briefings, or learn how our team serves banks, fintechs, charities, crypto businesses and MSBs.

Contact the Washington team
Integrated team

Related senior lawyers

Bring structure to the first critical decisions.

For urgent investigations, sanctions restrictions, cyber incidents, subpoenas or cross-border enforcement, contact the Washington team. Do not send privileged, classified or sensitive financial records before an engagement is confirmed.

Request a confidential consultation