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    West Coast AML Services is a risk management firm focused on building relationships between financial institutions and marijuana-related businesses (MRBs).



    Services Leadership
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    Our firm implements explicit and effective MRB risk management program components, conducts compliance reviews, recommends corrective actions, onboards MRBs, and provides training.



    Services Leadership
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    We craft proactive and preventive banking strategies to keep our clients in compliance in the rapidly-evolving regulatory and law enforcement environment surrounding the cannabis industry.



    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 Reviews

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.

Specialized Training

West Coast AML Services elevates BSA/AML training to a higher level. Our training curriculum focuses on the unique challenges of banking MRBs that financial institutions are confronted with on a daily basis. We provide specialized training on which to build a foundation for restructuring existing compliance programs to resemble those of highly proficient Financial Intelligence Units, but specific to MRB banking.

It is expected under the newly-appointed Attorney General, the Department of Justice will assess the quality and effectiveness of state and local regulatory and law enforcement environments when creating targeting priorities. West Coast AML Services was painstakingly designed by a former DOJ Asset Forfeiture and Money Laundering Senior Trial Attorney and I to protect the safety and soundness of financial institutions that bank MRBs. We minimize our client's risk of regulatory enforcement actions and prosecution under federal money laundering statutes (18 U.S.C. §§ 1956 and 1957).

Terry M. Neeley
Founder / Managing Director

Leadership

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

    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

    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

  • Franklin E. Worrell

    Franklin E. Worrell

    / Director of Onboarding - Oregon, Washington, and Nevada

    Frank investigated complex financial crimes and managed counter-terrorism matters for twenty-two years as a Special Agent with the Department of Justice, Federal Bureau of Investigation (FBI). As a Supervisory Special Agent, FBI Counter-Terrorism Headquarters in McLean, Virginia, Frank oversaw sensitive counter-terrorism matters for the FBI’s Philadelphia Division. He served as a field agent in Illinois, New Jersey and South Carolina and investigated financial institution failures, financial fraud schemes, healthcare fraud, insurance fraud and Ponzi schemes. While assigned to the FBI’s South Carolina Division, Frank investigated a fraudulent private investment fund where nearly 300 victims lost up to $66MM. The principal of this investigation was sentenced to twenty-four years in federal prison for orchestrating a Ponzi scheme and was ordered to pay restitution of $66.8MM.

    Frank served in a key management position in the Office of the Legal Attache, United States Embassy, Copenhagen, Denmark. There he oversaw sensitive joint counter-terrorism investigations involving the FBI and host country authorities in Denmark, Sweden and Norway.

    Following Frank’s career with the Department of Justice, he joined the Department of the Treasury, Special Inspector General for the Troubled Asset Relief Program (SIGTARP) for six years. He conducted some of SIGTARP’s most complex financial fraud investigations and spearheaded the agency’s investigative efforts to address concerns pertaining to potential and suspected fraud involving Treasury’s $26 billion Public Private Investment Program. Those investigations involved securities trading by some of the nation’s largest asset management companies. During that time, Frank worked closely with former federal prosecutors in SIGTARP’s Investigative Counsel Section, the Securities Exchange Commission and United States Attorneys Offices.

    The Departments of Justice and Treasury have commended Frank for superior achievement in complex criminal investigations. The Department of State and foreign government agencies commended Frank for his significant contributions in matters of mutual concern to the United States and its allies.

    Frank is a Certified Public Account (CPA) licensed in South Carolina, Certified in Financial Forensics (CFF), and a Certified Anti-Money Laundering Specialist (CAMS). He is a member of the American Institute of Certified Public Accountants, South Carolina Association of Certified Public Accountants, and Association of Anti-Money Laundering Specialists.

    Frank is a founder and principal of Quick Group, LLC, the premier Private Investigative firm in South Carolina. www.QuickGroupLLC.com

  • Anthony J. Macisco

    Anthony J. Macisco

    / Director of Training

    Tony is a former federal agent with 35 years of extensive operational, leadership and management experience in the Departments of the Treasury and Homeland Security. He conducted and supervised investigations of international drug money laundering organizations and was a charter executive board member that created a multi-agency task force to dismantle and prosecute U.S. based command and control centers for drug smuggling and money laundering organizations. In response to the terrorist attacks of September 11, Tony supervised Counter-Terrorist Financing investigations and undercover operations. His team identified, targeted and dismantled entities utilizing and exploiting financial institutions in violation of the USA PATRIOT Act and Bank Secrecy Act (BSA).

    Tony served as an Economic Crimes Advisor for Treasury providing guidance, mentoring and instruction in anti-money laundering and counter-terror financing methodologies in developing countries. He assisted countries develop their banking and law enforcement infrastructure to combat these crimes, including the creation and/or improvement of their Financial Intelligence Units (FIUs). He also provided BSA/AML training to numerous financial institutions in the U.S.

    Tony was a member of United States Attorney’s Office, Ohio, Law Enforcement Coordinating Committee; Corporate and Major Fraud Working Group; Bank Fraud Working Group; and a Charter Executive Board Member of the Anti-Terrorism Advisory Council. He was a Charter Executive Board Member of the Federal Bureau of Investigation Joint Terrorism Task Force, Ohio, and a Charter Member of the Homeland Security Strategic Analysis and Information Center, Ohio. Tony was a member of the American Bankers Association Security Director’s Council and appointed by Ohio Governor Kasich as a commission member to the Private Investigator Commission of the Department of Public Safety.

    Tony is an adjunct professor at Notre Dame College and assisted in the development of their Graduate Program of National Security and Intelligence Studies and teaches two courses: Leadership, Ethics and Decision-Making; and Critical Infrastructure Threat Analysis and Resiliency.

    Tony received numerous awards and recognition throughout his law enforcement career. The most notable was from the U.S. Congress for his undercover role as a money launderer in support of Operation C-Chase, a Treasury/Justice certified international covert operation resulting in over 100 arrests, seizure of $100MM cash, $500MM in fines levied and the closure of a bank registered in Luxembourg with head offices in London and Karachi, over 400 branches in 78 countries and $20B in assets

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