FinCEN Proposes Implementation of an Anti-Money Laundering Program

Recognized by the Euromoney Legal Media Group for her expertise in structured finance, Deborah Festa is a partner at Milbank, Tweed, Hadley & McCloy LLP. Through the Los Angeles firm, Deborah Festa handles investment management practices and West Coast securitizations. She offers financial institutions guidance on business finance structure and banking regulations.

In an effort to reduce risk in a multitrillion-dollar industry, the Financial Crimes Enforcement Network (FinCEN) in August 2015 proposed that all Registered Investment Advisers must implement an anti-money laundering program into their practice. This requirement also impacts sub-advisers and select asset and hedge fund managers.

If passed, the FinCEN proposal stipulates that an anti-money laundering program must include written policies and controls that are governed by a compliance committee. Periodic testing and ongoing training should also be incorporated to ensure investment practices always take a risk-based approach. This approach involves evaluating the type of client, source of funds, and investment services sought to determine intended use.                            

Vegetarian French Foods

Los Angeles attorney Deborah Festa brings more than a decade of legal experience to Milbank, Tweed, Hadley & McCloy LLP, where she leads as a partner. She provides counsel on regulatory and compliance matters to clients in the financial services industry. Away from work, Deborah Festa makes time to travel abroad, which has developed her passion for cooking French foods.

A French feast does not always include meat-based dishes. In fact, a spread of French lentils with walnuts and goat cheese, mushroom parmentier, and roasted beetroot and sauteed greens can make a great meal. The chef of Cooking Channel’s French Food at Home also suggests tomato and aubergine (eggplant) gratin.

The gratin consists of a sauce of onions, garlic, tomatoes, and pepperoncino cooked in olive oil. A bay leaf, various herbs, salt, and pepper season the sauce. Slices of eggplant are coated with olive oil and roasted in the oven until golden on each side. The sauce and eggplant slices are then layered into a dish, topped with a mixture of breadcrumbs and chili powder, and finished with a sprinkling of parmesan cheese. Baked in a hot oven for approximately half an hour, the vegetarian dish should be served straight from the oven.