Elizabeth T. DavyOf Counsel
Beth Davy is Of Counsel in the Financial Services and Financial Services Litigation and Investigations Groups and is co-head of the Economic Sanctions and Financial Crime Group. Her practice focuses on bank regulation and supervision, regulatory enforcement matters and internal investigations.
Ms. Davy is widely recognized as a leading expert in the areas of anti-money laundering (AML) and economic sanctions compliance and enforcement. She has represented numerous financial institutions in high profile global investigations involving multiple U.S. government agencies, as well as public and non-public regulatory enforcement matters. Chambers USA notes that Ms. Davy is “praised for her extensive experience of enforcement actions and internal investigations” and that their sources “call her ‘a fantastic lawyer,’” adding that she is “excellent on execution and strategy.”
Ms. Davy represents various financial institutions in the formation of industry utilities to enhance AML compliance. She has also worked with trade associations and industry representatives on establishment of industry standards and guidelines in the AML and sanctions compliance area and in the evolution of heightened transparency in the international payments system. She is a frequent speaker on issues relating to AML and economic sanctions.
Ms. Davy was a senior officer of the Federal Reserve Bank of New York’s Legal Department and Bank Supervision Group involved in regulatory and enforcement matters. While at the Federal Reserve, Ms. Davy served as Secretary to the Financial Markets Lawyers Group.
Ms. Davy also served as Deputy Superintendent and Counsel of the New York State Banking Department from 1991 to 1994.
Recent Speaking Engagements
- On June 9, Ms. Davy participated in a panel titled “Laundry List: An Analysis of the Anti-Money Laundering Act (AMLA) of 2020” as part of ACAMS 2021 New York Virtual Conference.
- On May 11, Ms. Davy participated in a panel titled “Legislative and Regulatory Update: The Future of BSA/AML” as part of PLI’s “Anti-Money Laundering 2021: Risks, Due Diligence and Compliance in an Evolving Legal World” program.
- On February 22, Ms. Davy participated in a sanctions roundtable hosted by the Council on Foreign Relations Corporate Program.
- On May 20, 2020, Ms. Davy participated in a webinar co-hosted with Kharon titled “Maritime & Russia Sanctions Risk,” which covered sanctions risks and OFAC regulatory expectations regarding the maritime industry.
Rankings and Recognitions
- Law360 – Banking MVP (2019)
- Financier Worldwide - International Trade & Sanctions 2020 Distinguished Adviser
- Chambers USA – recognized in Financial Services Enforcement & Investigations (2019-2021)
- The Best Lawyers in America – recognized in Banking Law (2007-2022)
- New York Super Lawyers – recognized as a Top Women Attorney in New York (2016, 2017) and in Banking Law (2007-2008, 2011-2012, 2014-2020)
- The Legal 500 United States – recognized in Financial Services: Regulatory (2012-2018)
- ABN AMRO Bank, Barclays, ING Group, Lloyds TSB Bank, Standard Chartered Bank, HSBC Group and BNP Paribas in the resolution of multiagency criminal and regulatory investigations relating to their compliance with economic sanctions and/or AML regulations.
- Citigroup, JP Morgan, Wells Fargo and U.S. Bank in resolving regulatory enforcement actions brought by the Federal Reserve and the Office of the Comptroller of the Currency (OCC) to address AML compliance program deficiencies.
- Danske Bank as U.S. counsel in relation to investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) of historical activity at its Estonian branch involving non-resident customers. The bank has previously reported that it identified a large volume of suspicious payments by non-resident customers of its Estonian branch, many of which were associated with alleged money laundering schemes. S&C is assisting the bank on its internal investigation and in responding to inquiries from U.S. authorities.
- Deutsche Bank regarding the investigations into suspicious securities trading and USD payments involving customers and counterparties of Deutsche Bank Moscow and Deutsche Bank AG (London Branch), as well as continuing to advise Deutsche with regards to ongoing matters related to those settlements and other ongoing investigations.
- Deutsche Bank regarding its $41 million settlement and consent cease and desist order in May 2017 with the Federal Reserve for AML deficiencies in its U.S. banking operations.
- JPMorgan Chase Bank N.A. in an approximately $5.26 million settlement in October 2018 with the Office of Foreign Assets Control (OFAC) for apparent violations of Cuban, Iranian and other sanctions relating to the net settlement of airline fees. OFAC gave JPMorgan mitigating credit for voluntary disclosure, and for its cooperation and remedial steps taken to prevent similar occurrences.
- Mashreq Bank in the October 2018 consent order with the New York Department of Financial Services (DFS) in connection with examinations and an investigation by the DFS into its AML program in its New York branch’s U.S. dollar clearing operations. As part of the order, Mashreq was ordered to pay a $40 million fine, revise its U.S. AML program, engage a third-party consultant to oversee its AML program remediation, and engage a look-back consultant to review transactions from 2016. In its announcement regarding the order, the DFS repeatedly commended Mashreq for its cooperation with the regulators and its willingness to improve its AML program compliance.
- Société Générale in connection with a Federal Reserve Board cease and desist order regarding the institution’s AML procedures.
- Standard Chartered Bank in a regulatory settlement with the DFS related to AML compliance.
- U.S. Bancorp in connection with the organization’s coordinated settlements with the U.S. Department of Justice, FinCEN, OCC and Federal Reserve Board related primarily to the bank’s AML compliance program and the activities of one of the bank’s customers who operated tribal payday lending businesses.
- Wachovia Bank in a $110 million deferred prosecution agreement with the Department of Justice, a civil resolution with FinCEN, and a $50 million civil money penalty with the OCC, related to AML compliance in Wachovia’s correspondent banking business.