Vesna K. Harasic-Yaksic

Obtained favorable settlement for European cryptocurrency trading platform in parallel civil and criminal investigation involving AML compliance failures. Secured declination from DOJ Fraud Section for a political strategist. Secured dismissal with prejudice for medical device company in qui tam suit involving Anti-Kickback Act (AKA) allegations. Obtained probationary sentence in lieu of incarceration for an individual convicted of embezzlement in the District Court for the Eastern District of Virginia. Obtained dismissal by relator in qui tam suit against a large defense contractor in the District Court for the Eastern District of Virginia. Secured declination by DOJ Antitrust Division for a Fortune 500 Company.

Represented European cryptocurrency trading platform in money laundering investigation and related forfeiture proceedings. Represented a Chief Operating Officer in connection with bribery allegations involving Department of Veteran Affairs contracts. Represented various individuals in FCPA investigation involving Afghanistan. Represented entity in Special Counsel investigation. Represented an individual in connection with an investigation by the U.S. Attorney’s Office for the Eastern District of Virginia relating to conduit campaign contributions. Represented executive in an investigation by the U.S. Attorney’s Office for the District of Columbia involving allegations of public corruption and procurement fraud. Represented an insurance company in an FCA investigation involving alleged false certifications of eligibility for government contracts. Representing HUBZone contractor related to potential False Claims Act violations. Represented a foreign financial executive in connection with parallel SEC/DOJ investigations of accounting fraud. Representing an international company in an Anti-Terrorism Act suit arising from the performance of government defense contracts in Afghanistan. Representing a government contractor in connection with an Office of Inspector General (OIG) investigation. Represented a company in a time fraud investigation involving a waste treatment facility. Represented a defense company operating in Iraq related to false certifications under a large government contract. Represented a military contractor and its executives against allegations of fraud, misappropriation, and business torts.

Advises various companies on CTA requirements and developments. Conducted full-scale AML/CFT compliance program review for foreign telecommunications provider operating mobile money platform. Advised international association on the applicability of money services business (MSB) regulations in connection with a payment platform. Advised video game developer on the implementation of adequate AML/BSA controls for in-game currency. Counseled asset management firm on AML risks associated with investment opportunity. Analyzed the applicability of AML rules to gift card program of a public company. Advised European trading platform on implementation of “Know Your Customer” procedures for U.S. customers. Counseled a scientific research organization regarding its AML compliance obligations in relation to a government subcontract. Advised a Fortune 500 company on antitrust compliance policy and electronic data preservation issues. Advise multiple clients on compliance issues related to law enforcement data requests, including responding to subpoenas, 2703(d) orders, and search warrants.

Represented a company in domestic arbitration involving environmental remediation issues. Represented a large real estate developer in an arbitration seated in Singapore involving a joint venture agreement to build an entire foreign city.

Represented the United States in complex money laundering prosecutions and grand jury investigations, including the investigation of a large-scale money laundering organization operating a black-market peso exchange. Those investigations involved grand jury subpoenas, search and seizure warrants, wiretaps, surveillance, and other law enforcement tools. Represented the United States in civil forfeiture matters including the successful forfeiture of nearly $1 million dollars in insurance fraud proceeds. Assisted in the investigation of financial institutions for AML/BSA violations and failures to implement effective anti-money laundering compliance programs and controls.

Represented the United States in the prosecution of an individual for fraud and money laundering offenses involving U.S. Agency for International Development (USAID) foreign assistance funds in Africa. Provided forfeiture assistance to AUSAs in more than 30 federal criminal cases including fraud, bank robbery, narcotics trafficking, and sex offenses. Represented the United States in a civil forfeiture proceeding against an aircraft engine intended for illegal re-export to Iran in violation of the International Emergency Economic Powers Act (IEEPA) and other U.S. sanctions violations. Participated in a grand jury investigation of a foreign company involved in money laundering and IEEPA violations.

Lead counsel for the prosecution of an individual charged with bulk cash smuggling and false statements. Represented the United States in the prosecution of a large-scale visa fraud scheme. Represented the United States in the prosecution of various misdemeanors on federal land. Represented the United States in supervised release and probation violation hearings.

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule (IFR) that materially alters the Corporate Transparency Act’s (CTA) reporting requirements. Consistent with FinCEN’s March 2, 2025 announcement (discussed here), the IFR exempts U.S. companies and persons from the CTA’s requirements, thereby relieving millions of businesses of the significant compliance burden associated with preparing and filing beneficial ownership information (BOI) reports. In fact, using FinCEN’s own estimates, the IFR decreases the number of reporting companies from roughly 32 million to just under 12,000.

On March 2, 2025, the U.S. Department of the Treasury issued a press release stating that it will not enforce any penalties or fines against U.S. citizens or domestic reporting companies under the Corporate Transparency Act (CTA).

As discussed here last month, in early January, the U.S. District Court for the Eastern District of Texas issued a nationwide injunction temporarily blocking enforcement of the Corporate Transparency Act (CTA) (see Smith et al. v. DOT et al., No. 6:24-cv-336). However, in light of the U.S. Supreme Court’s decision to overturn a similar injunction in a separate case involving the CTA (McHenry v. Texas Top Cop Shop, Inc.), on February 18, 2025, the Smith court granted the government’s request to stay the nationwide injunction, while a Fifth Circuit appeal moves forward.

Late on February 10, President Trump ordered Attorney General Pam Bondi to “pause” new Foreign Corrupt Practices Act (FCPA) enforcement for 180 days while the U.S. Department of Justice (DOJ) refocuses criminal enforcement of the statute. The Executive Order is potentially among the most significant enforcement developments related to the FCPA in years. While the directive is specific to DOJ criminal enforcement of the FCPA, the order and recent memoranda issued by Attorney General Bondi signal shifting tides in the FCPA landscape. With more to come from DOJ, and possibly the U.S. Securities and Exchange Commission (SEC) under new leadership, companies should monitor new guidance before updating their FCPA compliance programs.

On February 5, newly confirmed Attorney General Pam Bondi issued a series of guidance documents refocusing U.S. Department of Justice (DOJ) priorities for the new Administration. In addition to effectuating many of President Trump’s Executive Orders, Attorney General Bondi reinstituted prior Trump Administration guidance, established working groups and task forces, and reallocated Department resources. Importantly, many Executive Orders impact enforcement priorities and DOJ components tasked with traditional white collar enforcement. With more changes likely coming, companies should evaluate whether these policy changes could impact ongoing or future matters with the Department as well as existing compliance programs.

In this episode, Wiley attorneys Vesna Harasic-Yaksic and Ira Mirsky dive into the latest developments with litigation over the Corporate Transparency Act (CTA) and potential roads ahead. They also explore its origins, implications for businesses, and complexities of compliance. They discuss reporting requirements, exemptions, and how small businesses, in particular, are impacted.

Wiley Connected | Internet of Things Law and Policy, Explained. In this episode of Wiley Connected, Vesna Harasic-Yaksic discusses the Supreme Court’s recent decision in Carpenter v. United States, and its implications on telecommunications providers, ISPs, and other IoT industry companies.