Constantine advises financial services clients on Bank Secrecy Act/Anti-Money Laundering (BSA/AML), digital currency, blockchain, and other banking regulatory issues before the federal banking agencies and the Financial Crimes Enforcement Network (FinCEN.) He also uses his extensive experience as a former federal and state prosecutor to advise companies and individuals in government investigations and enforcement matters. Constantine’s unique regulatory and litigation background provides a strong foundation to assist clients in addressing compliance and litigation risk and in defending companies and individuals facing government scrutiny.
As the FDIC's Lead Counsel for BSA/AML matters, Constantine regularly provided legal advice and analysis on emerging issues such as suspicious activity reporting, customer identification programs, blockchain, digital currency, Bitcoin ATMs, and marijuana-related banking. Constantine also helped implement the Anti-Money Laundering Act of 2020, the most significant update to the government’s anti-money laundering legal framework since 2001. This new act will result in new bank regulations for BSA/AML compliance programs, customer due diligence and beneficial ownership reporting. He regularly coordinated matters with the Federal Reserve, FinCEN, National Credit Union Association (NCUA) and Office of the Comptroller of the Currency (OCC).
At the FDIC, Constantine co-led the investigation into systemic BSA/AML violations at a large international financial institution that resulted in a $140 million civil money penalty.
Prior to his time at the FDIC, Constantine served as a Trial Attorney at the U.S. Department of Justice working in the Money Laundering and Asset Recovery Section. There, he led a long-term investigation of payment processing fraud at a major U.S. institution, resulting in a deferred prosecution agreement and a $160 million forfeiture. He also investigated anti-money laundering compliance failures involving public corruption, and partnered with the Fraud Section and the Organized Crime and Gang Section on separate occasions to prosecute money laundering and healthcare fraud in South Florida health care clinics.
Constantine also has experience at the state level, serving as an Assistant State’s Attorney for the Montgomery County State’s Attorney’s Office in Rockville, Maryland. Across his time in government, Constantine litigated 21 state and two federal criminal jury trials.
Admitted in Maryland only. Practice in the District of Columbia limited either consistent with Rule 49(c) of the Rules of the District of Columbia Court of Appeals or subject to the supervision of a D.C. Bar member.
RECENT PUBLICATIONS + SPEAKING ENGAGEMENTS
- “FinCEN Alerts On Sanctions Evasion Signal Shifting Approach,” Law360, March 2022
- “Federal Financial Regulators Issue Warnings About Russian Sanction Evasion Attempts,” Harris Beach Legal Alert, March 2022
- 2021 University of North Carolina Center for Banking and Finance, What’s the Buzz: Current Trends and Supervisory Expectations in Cannabis and Hemp Banking
- 2020 FFIEC BSA/AML Specialists Conference, Case Study: Banamex USA
- 2020 DOJ’s Advanced AML Training, Columbia, S.C., Payment Options – The New Frontier
- 2019 Mid-Sized Bank Coalition of America, Dallas, TX, Interagency BSA/AML Regulatory Reform Update
- 2018 FDIC/DOJ Financial Crimes Conference, Arlington, VA, FDIC’s Investigation of Banamex USA
- 2016 ABA Business Law Section Annual Meeting, Boston, MA, Trends in Personal Liability for In-House Compliance Professionals
- Homeland Security Investigations Mid-Atlantic Anti-Money Laundering Conference, Washington, D.C., Liability of Bank Compliance Officers for BSA Violations, 2014
