Andrew S. Ittleman is a founding partner of Fuerst Ittleman David & Joseph. He is an attorney and Certified Anti-Money Laundering Specialist providing strategic representation to a wide variety of regulated businesses, their executives and officers, and other related individuals.
Mr. Ittleman has represented a broad range of domestic and international financial and money services businesses (MSBs), including:
- Money transmitting businesses
- Check cashing businesses
- Currency exchangers
- Foreign exchange (ForEx) dealers
- Prepaid card and other prepaid access providers
- Payment facilitators (PayFacs) and Independent Sales Organizations (ISOs)
- Cryptocurrency dealers, exchangers and issuers, both online and via ATM machines and
- Financial technology (FinTech) firms
Mr. Ittleman has represented his financial services and MSB clients in the following capacities:
- Regulatory counseling, including by assisting early stage financial services and FinTech firms understand state, federal and international regulations, as well as by assisting clients make strategic business decisions in light of overarching regulatory concerns
- Anti-money laundering counseling, including by advising MSBs regarding marijuana-related business (MRB) and other high risk customers
Stock and asset purchase agreements, including by conducting regulatory due diligences on behalf of purchasers of entities and assets - Agency, foreign affiliate, and other cooperation agreements between regulated financial institutions
- Website and mobile application User Agreements, Terms of Service and Privacy Policies, including by advising clients regarding their use of customer information
CFPB disclosure requirements - OFAC sanctions regulations, including most recently the U.S. government’s Venezuelan sanctions program and its shifting policies governing remittances to Cuba
- Entity formation, including by drafting and negotiating governing documents and employment agreements
- Money transmitting license applications
- Commercial litigation
- White collar criminal defense and grand jury investigations involving allegations of money laundering, operating unlicensed money transmitting businesses, CMIR violations, and related allegations of wrongdoing
- Government (civil) enforcement litigation
- Law enforcement relations, including by assisting domestic and international clients respond to grand jury subpoenas and Mutual Legal Assistance Treaty (MLAT) requests
- State and federal enforcement actions, including administrative complaints filed by FinCEN, CFTC, and state-level financial services regulators
Mr. Ittleman has also advised multinational banks and domestic credit unions develop policies and procedures for their banking of MSBs, FinTech firms, marijuana related businesses, and other high risk accountholders.