People

Benjamin Hutten 合伙人

New York

Ben has a deep understanding of sanctions and AML regulations and enforcement. In addition to his client work, he has participated in numerous financial industry group regulatory initiatives related to sanctions and AML issues, including The Clearing House Guiding Principles for Anti-Money Laundering Policies and Procedures in Correspondent Banking, initiatives to address “de-risking” and related to BSA information sharing. Ben also conducts international trainings in AML and sanctions issues for the Financial Services Volunteer Corps.

He has been recognized by Best Lawyers in America as "One to Watch" and by Super Lawyers as a "Rising Star." Prior to joining Orrick, Ben was counsel at Buckley LLP and an associate at Sullivan & Cromwell LLP.

Jeanine P. McGuinness 合伙人

Washington, D.C.

Jeanine’s clients include major U.S. and foreign financial institutions, and pharmaceutical, technology, telecommunications, energy, and natural resources companies.

Examples of Jeanine’s experience include:

• Represents clients in preparing voluntary self-disclosures, administrative subpoena responses and license applications, and represents companies in connection with enforcement actions by the Treasury Department’s Office of Foreign Assets Control (OFAC)
• Provides policy and compliance advice to clients affected by frequent changes in U.S. sanctions, including sanctions targeting Iran, Cuba, and Russia/Ukraine
• Assists foreign purchasers of U.S. companies in national security reviews, including navigating the CFIUS process, through preparation of notices, meetings with CFIUS member agencies, advising on follow-on investigations, and negotiating and implementing mitigation agreements
• Assists clients in developing and updating economic sanctions, anti-money laundering, and anti-corruption compliance policies and procedures
• Represents financial institutions in connection with U.S. federal and state enforcement actions regarding compliance with U.S. anti-money laundering laws and regulations
• Represents lenders, underwriters, borrowers, and issuers in international lending and capital markets transactions regarding sanctions, anti-corruption, and anti-money laundering issues
• Advises a U.S. trade association and its member banks regarding U.S. sanctions, anti-corruption, and anti-money laundering issues in lending transactions, and prepares guidance for the industry on these matters
• Advises financial institutions on the application of U.S. anti-money laundering regulations, with specific emphasis on customer identification program (CIP)/know your customer (KYC)/customer due diligence (CDD) requirements and suspicious activity reporting requirements
• Regularly advises private equity and hedge funds regarding compliance with U.S. anti-money laundering and sanctions laws and regulations, including with respect to appropriate provisions in subscription materials and enhanced due diligence on high-risk investors
• Advises clients regarding sanctions-related inquiries from the Securities and Exchange Commission (SEC) and state agencies implementing divestment laws and assists clients in preparing sanctions-related disclosure for inclusion in annual reports to the SEC

Jeanine is ranked in both the CFIUS Experts and Export Controls & Economic Sanctions categories by Chambers USA in 2019, 2020, 2021, and 2022. An interviewee had this to say of their experience working with Jeanine, “I am continuously impressed by her extensive knowledge, excellent communication skills and her ability to wrap her subject matter expertise around the details of the matter and then drive conclusions or recommendations for next steps."

Amy Walsh 合伙人

New York

Amy represents individuals and institutions in government investigations, enforcement actions and prosecutions conducted by the U.S. Department of Justice (DOJ), the Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC) and the Internal Revenue Service. She negotiates resolutions with government officials, but also tries cases against the government. She is a fierce advocate for her clients, and her work often results in the government declining to bring charges.

Amy was an Assistant United States Attorney for 12 years in the United States Attorney’s Office for the Eastern District of New York, where she led dozens of investigations and cases on behalf of the U.S. government and supervised several sections within the Office.

Amy has also served as a court-appointed monitor for a global financial institution.