Verified profile

AnnaLou Tirol

AML Lawyer & Former FinCEN’s Deputy Director

AnnaLou Tirol's profile photo
LocationWashingtonDistrict of Columbia, United States
Current rolePartnerO'Melveny & Myers LLP · since Oct 2022
Government service15yrsU.S. Department of the Treasury · U.S. Department of Justice (DOJ) · U.S. District Court · U.S. Attorney’s Office

About

AnnaLou Tirol counsels clients on anti-money laundering (AML) and fintech regulatory, compliance, and enforcement issues, drawing on two decades of government experience, most recently as Deputy Director of the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN).

Few lawyers share AnnaLou’s deep familiarity with AML laws and regulations. As FinCEN’s Deputy Director, the bureau’s second highest official, AnnaLou oversaw FinCEN’s operations, programs, and policy, including legislative and regulatory matters, public-private partnerships with financial institutions and fintechs, and enforcement and compliance matters related to the Bank Secrecy Act (BSA). Following Congress’ January 2020 enactment of the Anti-Money Laundering Act of 2020, AnnaLou led FinCEN’s implementation of the most significant legislation to modernize the BSA since the USA PATRIOT Act, including the Corporate Transparency Act’s beneficial ownership requirements.

Prior to joining FinCEN, AnnaLou served as the Acting Chief of the Public Integrity Section of the U.S. Department of Justice’s (DOJ) Criminal Division from 2016 to 2019. In that role, she oversaw approximately 35 prosecutors litigating sensitive and complex public corruption and election crimes cases nationwide. In her 15 years with DOJ, AnnaLou served in multiple capacities, including as an Assistant U.S. Attorney in the Southern District of California, leading complex white collar investigations and prosecutions involving financial fraud, public corruption, money laundering, and other crimes, and trying 15 jury trials to verdict. She also served as an overseas Legal Advisor for DOJ, running rule of law programs targeting money laundering, public corruption, terrorist financing, fraud, and financial crimes in Panama City, Panama and Belgrade, Serbia.

AnnaLou is also committed to mentoring and developing young and diverse attorneys. She is an Adjunct Professor of Law at Georgetown University Law Center and was a founding member of FinCEN’s Women’s Leadership Series

Roles

Oct 2022–Present
Current role

Partner

O'Melveny & Myers LLP

Washington, District of Columbia

Foreign Corrupt Practices Act (FCPA)Civil LitigationPrivacy LawBusiness / Corporate ServicesRegulatory SpecialistSecurities LawWhite Collar CrimeNational Security LawInformation Technology (IT)Corporate Law

Jan 2019–Jan 2022
Former role

Associate Director

U.S. Department of the Treasury, Financial Crimes Enforcement Network | Strategic Operations Division

(appointed)District of Columbia

Civil LitigationSecurity and Law EnforcementLegal Officers and PractitionersNational Security LawCorporate LawCriminal InvestigationTax Law
Jan 2019–Jan 2022
Former role

Deputy Director

U.S. Department of the Treasury, Financial Crimes Enforcement Network

(appointed)District of Columbia

Foreign Corrupt Practices Act (FCPA)Civil LitigationFederal GovernmentEnforcementSecurities LawWhite Collar CrimeCorporate LawAccounting Assistant
Jan 2019–Jan 2016
Former role

Acting Chief, Principal Deputy Chief

U.S. Department of Justice (DOJ), Public Integrity Section, Criminal Division

(appointed)District of Columbia

Jan 2011–Jan 2016
Former role

Resident Legal Advisor, AML/CFT, Anti-Corruption

U.S. Department of Justice (DOJ), Criminal Division

(appointed)Panama City, District of Columbia, Panama

Attorney Advisor

Jan 2011–Jan 2016
Former role

Resident Legal Advisor, AML/CFT, Anti-Corruption

Criminal Division

(appointed)Belgrade, Serbia

Attorney Advisor
Jan 2007–Jan 2009
Former role

Trial Attorney

U.S. Department of Justice (DOJ), Public Integrity Section

(appointed)District of Columbia

ResearchLegal Assistance
Jan 2007–Jan 2006
Former role

Law Clerk

U.S. District Court

(appointed)California

Law ClerkResearchInvestigations

Served as judicial law clerk to the Honorable Ruben B. Brooks, U.S. Magistrate Judge, researching and drafting opinions, orders, and bench memoranda.

Jan 2007–Jan 2009
Former role

Trial attorney

U.S. Department of Justice (DOJ), Public Integrity Section

(appointed)District of Columbia

White Collar CrimeLegal
Jan 2004–Jan 2013
Former role

Assistant U.S. Attorney

U.S. Attorney’s Office, United States Attorneys'​ Offices , San Diego

(appointed)California

Civil LitigationLegal Assistant

Representative matters

Government Experience

April 2025

Deputy Director, Financial Crimes Enforcement Network, U.S. Department of the Treasury. Acting Chief, Public Integrity Section, Criminal Division, U.S. Department of Justice. Assistant U.S. Attorney, U.S. Attorney’s Office, Southern District of California. Resident Legal Advisor, Office of Overseas Prosecutorial Development, Assistance and Training, Criminal Division, U.S. Department of Justice.

Recognition

Honors

Distinguished Service Award

U.S. Department of the Treasury

March 2025

Meritorious Honor Award

U.S. Department of State

March 2025

Award for Distinguished Service

Assistant Attorney General

March 2025

FinCEN Director’s Award for Excellence in Diversity and Inclusion

FinCEN

March 2025

Publications & speeches

Corporate Transparency Act Requirements Eliminated for U.S. Companies and U.S. Persons

O'Melveny & Myers LLP

March 2025

Link

Corporate Transparency Act Deadlines to be Extended by New Regulation

O'Melveny & Myers LLP

February 2025

Link

Corporate Transparency Act Reinstated – Compliance Deadline Extended to March 21 for Most Companies

O'Melveny & Myers LLP

February 2025

Link

President Trump Issues Executive Order to Establish Digital Assets Regulatory Framework

O'Melveny & Myers LLP

February 2025

Link

New Executive Order Targeting Cartels Could Increase Enforcement Risks for U.S. Companies Operating in Mexico

O'Melveny & Myers LLP

January 2025

Link

Regulatory Fireside Chat Discussion

ACAMS South Florida Chapter Financial Crime Forum

November 2024

Women in Risk (WIRE) Breakfast

ACAMS South Florida Chapter Financial Crime Forum

November 2024

Masterclass: Implementing the U.S. National Priorities

ACAMS Webinar

November 2024

International Reporting, Compliance & Enforcement

16th Annual STEP International Tax and Estate Planning Forum

June 2024

Corporate Transparency Act (CTA) Update

New York Bar Association

May 2024

The CTA and LLC Transparency Act – Where Are We Now

Business Law Section and Corporate Counsel Section NYSBA Annual Meeting

January 2024

The Corporate Transparency Act—Dealing with the New World of Beneficial Ownership and Control Disclosure

82nd Institute on Federal Taxation

November 2023