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    West Coast AML Services maximizes the effectiveness of Bank Secrecy Act/Anti-Money Laundering risk management programs.

    Services Leadership
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    Our firm implements explicit and effective Marijuana-Related Businesses/Anti-Money Laundering components in risk management programs.

    Services Leadership
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    West Coast AML Services crafts proactive and preventive strategies in connection with high-risk cannabis compliance.

    Services Leadership

Our Services

Our foremost concern is the safety and soundness of the financial institution.

Strengthening Risk Management Programs

West Coast AML Services implements explicit and effective Marijuana-Related Businesses (MRB)/Anti-Money Laundering (AML) components in financial institutions' risk management programs. Our firm does this in accordance with former Department of Justice Deputy Attorney General James Cole's memorandums, the Financial Crimes Enforcement Network (FinCEN) Bank Secrecy Act (BSA) expectations along with other federal and state regulations.

Onboarding Marijuana-Related Businesses

West Coast AML Services does not perform work for MRBs. On behalf of the financial sector, our firm conducts careful on-site examinations of MRBs to ensure critical criteria for effective AML compliance are in-place and properly administered. We deep dive to uncover risky vulnerabilities, spot weaknesses that may require immediate corrective actions, and recommend enhancements to existing programs.

Project Management

Community banks and credit unions often lack sufficient resources necessary to properly manage a large scale, high-risk customer base. West Coast AML Services crafts proactive and preventive strategies and temporarily manages high-risk compliance programs. Our firm provides workforce augmentation to conduct enhanced due diligence, quality control, Customer Identification Program (CIP), reduce backlog and prepare Suspicious Activity Reports (SARs) until the financial institution can effectively manage its compliance program.

Reputational Risk

For the last several years, many of our team members conducted complex grand jury investigations of financial institutions under the U.S Treasury Department's Capital Purchase Program, commonly referred to as the "Bank Bailout." Through extensive interactions with boards, bank officers and regulators we have strengthened our banking industry expertise and gained insight as to the many potential reputational risks financial institutions face today.

Prosecution Mitigation Review

West Coast AML Services examines existing MRB compliance programs with firsthand insight into the prosecution of financial institutions and bankers by the Department of Justice under federal money laundering statutes (18 U.S.C. §§ 1956 and 1957). We recommend program enhancements, immediate corrective actions, tailor training for BSA officers and senior management, and advise the Board on oversight. Prosecution Mitigation Reviews keep our clients from running afoul of the Department of Justice, FinCEN and law enforcement.

Attorney General Jeff Sessions has criticized FBI Director James Comey and Attorneys General Eric Holder and Loretta Lynch for not vigorously enforcing the prohibition on marijuana. Going forward, we expect DOJ to closely scrutinize regulatory environments in pro-marijuana states and set new law enforcement targeting policies. It is imperative for any financial institution banking marijuana to carefully craft enhanced due diligence programs for this unique high-risk customer base. West Coast AML Services was designed solely to protect the safety and soundness of financial institutions that bank MRBs.

Terry M. Neeley
Founder / Managing Director


Our team brings a wealth of knowledge and expertise to the table with varying backgrounds in Federal law enforcement, banking, compliance and certifications, including Anti-Money Laundering Specialist (CAMS), Fraud Examiner (CFE), Public Accountant (CPA), and Forensic Interviewer (CFI). Many held Top Secret security clearances when they were federal government employees.

  • Terry M. Neeley

    / Founder and Managing Director

    Terry is a well-respected expert in the federal law enforcement Bank Secrecy Act/Money Laundering Control Act (BSA/AML) field with over 25 years of firsthand experience investigating complex drug money laundering organizations, white collar financial crimes and terrorist financing. Concerned about marijuana-related businesses (MRBs) banking issues, Terry established West Coast AML Services to minimize the complex risks for financial institutions in an effort to help compliant MRBs receive banking services.

    In August 2016, Terry concluded a six-year position with the U.S. Department of the Treasury, Special Inspector General for the Troubled Asset Relief Program (SIGTARP). He worked hand in glove with U.S. Department of Justice prosecutors and the Federal Deposit Insurance Corporation, Inspector General, conducting highly complex grand jury investigations and prosecutions of financial institutions and bankers under the Treasury Department’s $850 billion "Bank Bailout."

    Prior to SIGTARP, Terry held several leadership positions in anti-drug money laundering divisions within Treasury. He was a key figure in the most significant drug money laundering investigation in U.S. history, which involved the indictment of foreign banks for violations of the BSA/AML and the arrest of two-dozen bankers. He successfully directed enterprise-wide undercover financial task force operations against Mexico and Colombia drug cartels. He served at the U.S. Embassy Ottawa, Canada and Den Haag, The Netherlands, and briefed trade based anti-money laundering operations he ran to U.S. Ambassadors in Colombia and Panama, members of Congress, senior management at the Treasury and Justice Departments and Italy’s Anti-Mafia.

    Terry was the Department of Homeland Security Regional Coordinator for the Organized Crime Drug Enforcement Task Force Program, U.S. Attorney's Office, Northern District of California, Anti-Drug Money Laundering Task Force Director Chicago, Baltimore and Los Angeles and founding director of the San Francisco High Intensity Financial Crimes Area/SAR Task Force.

    Terry supervised Counter-Terrorist Financing investigations and undercover operations in response to the September 11, 2001, terrorist attack. He created and implemented strategies to identify, target and dismantle Informal Value Transfer Systems (Hawalas) utilizing financial institutions in violation of BSA, USA PATRIOT Act and other federal statutes.

  • Jonathan R. Howden, Esquire

    / Of Counsel

    Jonathan was an Assistant United States Attorney (federal prosecutor) for 25 years, first for the Antitrust Division of the Department of Justice and then with the United States Attorney’s Office in the Northern District of California, where he was involved in the investigation, prosecution and trial of virtually every variety of federal criminal violation. He did tours with the White Collar Crime section, the Computer Hacking and Intellectual Property section and the Asset Forfeiture section.

    Jonathan was the Department of Justice Pacific Region Coordinator for the Organized Crime Drug Enforcement Task Force Program, overseeing major narcotics and drug money laundering investigations throughout the Western United States.

    As a result of Jonathan’s role in the successful prosecution and trial of the former Prime Minister of Ukraine (Pavel Lazerenko) on international money laundering, wire fraud and stolen property charges, he received the Attorney General’s Distinguished Service Award, the highest honor bestowed upon federal prosecutors.

    Jonathan has been in private practice since 2005, first as a Partner at Thelen LLP and then as a Partner at Winston & Strawn. He opened his current practice in late 2011. Jonathan successfully represented companies and individuals in international antitrust investigations, fraud, international money laundering, high tech, environmental, and international bribery investigations.

    In January 2011, Jonathan led a trial team in defending a Canadian company and its President and CEO in a jury trial in which the Antitrust Division charged the defendants with wire fraud and money laundering relating to a defense subcontract. The defense was so effective that the judge granted a directed verdict of acquittal to all of the defendants on all of the charges at the close of the government’s case. Such verdicts are extremely rare and are only granted when the defense has completely dismantled the government’s case, such that “no reasonable juror could find guilt beyond a reasonable doubt.”

    Jonathan was selected a white collar crimes "Super Lawyer" in California for 2015 and 2016. His law practice is based in San Francisco, California - www.HowdenLaw.com

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