• Carol R. Van Cleef

    Co-chair, Global Payments
    Financial Services and Banking
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    Direct: 202.585.6520
    General: 202.585.6500
    Fax: 202.585.6600


    American University Washington College of Law, J.D., 1984.

    Georgetown University, B.S.F.S., 1978. 

    Bar Admissions

    District of Columbia


    • Profile
    • Representative Matters
    • Honors & Awards
    • Publications
    • Memberships & Activities
    • Speaking Engagements


    Carol Van Cleef is co-chair of the Global Payments practice group and a member of the Financial Services and Banking practice. She represents financial services companies and other clients in federal and state regulatory, compliance, and enforcement matters, including anti-money laundering, electronic payments, federal deposit insurance, and other bank regulatory issues. She counsels banking organizations, credit unions, securities firms, insurance companies, finance companies, money service businesses and hedge funds, among others.

    Ms. Van Cleef has significant experience working with all types of MSBs (including domestic and foreign money remitters, bill payment systems, check cashers, currency dealers/exchangers), third-party payment processors, stored value (prepaid card) programs, and other alternative payment systems regarding state money transmitter licensing and regulatory requirements, federal MSB registration, BSA/AML compliance, privacy and information security programs. She has represented publicly traded companies and private equity funds in purchasing and selling bill payment companies, money transmitters and other types of money services businesses. Ms. Van Cleef also has worked closely with the management and shareholders of money services businesses seeking new funding sources and confronting bankruptcy. She is the author of the legal/regulatory section of the National Automated Clearing House Association's popular 2007 Guidelines for Billers and Walk-in Payment Providers. A Certified Anti-Money Laundering Specialist, Ms. Van Cleef is a frequent speaker on AML compliance-related issues and a member of the Editorial Task Force of ACAMS Today. She has created a series of highly acclaimed AML compliance training programs sponsored by the Conference of State Bank Supervisors, including the Boot Camp for BSA/AML Compliance Professionals, the Mini-Boot Camp for Developing Prepaid Card AML Compliance Programs, and an intermediate course, Officer Training for BSA/AML Professionals. These programs have been attended by regulators from more than 45 states and representatives of domestic and foreign banks, securities firms, MSBs and other companies.

    Ms. Van Cleef regularly advises clients on compliance with the USA Patriot Act, the Bank Secrecy Act, and Office of Foreign Assets Control regulations. She assists clients in developing, reviewing, and enhancing BSA, AML, and OFAC compliance programs. She also works with clients in analyzing implementation of their automated BSA/AML compliance solutions, addressing enforcement actions and preparing for regulatory examinations and independent compliance reviews.

    A veteran of the savings and loan crisis, Ms. Van Cleef has represented more than 50 banking organizations on a number of federal deposit insurance assessments and coverage issues. She has worked with numerous banks and savings institutions on various types of transactions involving failing and failed depository institutions, asset acquisitions, and contracting to provide services to receivers or conservators. She also served as special regulatory counsel for the holding company of a failed bank in federal bankruptcy proceedings.

    In addition to CSBS, Ms. Van Cleef works closely with the Money Transmitter Regulators Association and the National Association of State Credit Union Supervisors. She is an active member of NACHA's Council for Electronic Billing and Payment. Ms. Van Cleef has served as the vice-chair of the Legislative Process and Lobbying Committee of the American Bar Association's Administrative Law and Regulatory Practice Section and a member of the Executive Committee of the Federal Bar Association's Banking Law Committee. She is a past president of Women in Housing and Finance.

    Prior to practicing law, Ms. Van Cleef was a consultant with the bank consulting firm Golembe Associates, Inc.

    Representative Matters

    Honors & Awards


    Regularly called upon by national, business and trade publications to share her expertise in the global payments and financial services and banking industry, Ms. Van Cleef's commentary has appeared in The New York Times, The Wall Street Journal, Wired, Thomson Reuters, Credit Union Times, Law360, and includes the following articles:

    Contributor, "Payments and Customer Experience: Best Practices Guide," ATM Industry Association, 2013.

    "A Game Plan for Addressing FinCEN's New Prepaid Access Rule," Paybefore.com, March 31, 2012.

    Bank Secrecy Act and Anti-Money Laundering Compliance, "Mortgage Finance Regulation Answer Book 2011-12," Practising Law Institute, June 2011.

    "Tackling the AML Compliance Challenges of Emerging Payment Alternatives: Follow the Yellow (Gold) Brick Road Into Digital Currencies, Part I," ACAMS Today, March-May 2011.

    Coauthor, "The Assault Continues - Prepaid Cards Included in Senate's Financial Services Reform Bill," The Prepaid Press, June 15, 2010.

    Coauthor, "Federal Rules Put Prepaid Cards in Line of Fire - Impose New Burdens on Merchants," The Prepaid Press, May 15, 2010.

    Author, "Federal Financial Regulatory Reform: New Proposal Includes Prepaid Products," The Prepaid Press, August 13, 2009.

    Coauthor, "Insights: New MSB Examination Manual Challenges Regulators, Industry and Banks," Fortent Inform, April 1, 2009.

    Memberships & Activities

    Admitted to practice in the District of Columbia.

    Admitted to practice in Virginia.

    Member, Integrated Payments Alliance Advisory Board.

    Member, Integrated Payments Standards Forum.

    National Automated Clearing House Association, Council for Electronic Billing and Payment.

    Former Vice-chair, Legislative Process and Lobbying Committee of the Administrative Law and Regulatory Practice Section, American Bar Association.

    Former Executive Committee Member, Federal Bar Association, Banking Law Committee.

    Past President, Women in Housing and Finance.

    Association of Anti-Money Laundering Specialists (ACAMS).

    American Bar Association.

    Speaking Engagements

    Panelist, “Security, Identity and Law Enforcement in the Age of Bitcoin, Crypto Currencies and the Blockchain,” SINET Showcase, Washington, D.C., November 3, 2015.

    Moderator, “AML & OFAC in the New Payments Landscape,” Money 20/20, Las Vegas, NV, October 25, 2015.

    Panelist, “Anti-Money Laundering and Know-Your-Customer Compliance For Digital Currencies; Current State and Outlook,” GM Insight’s Digital Currencies Conference, New York, NY, September 30, 2015.

    Speaker, “OFAC Need to Know: Cuba, Iran and More—New Opportunities and Challenges,” Payments Innovation Alliance Meeting, Miami, FL, September 29, 2015.

    Speaker, “Making Bitcoin a Crime: Recent Prosecutions of Unlicensed Money Transmitters Under the PATRIOT Act,” ABA Business Law Section Annual Meeting, Chicago, IL, September 18, 2015.

    Panelist, “Sharing Information and Issues of Data Protection,” Cambridge International Symposium on Economic Crime, University of Cambridge, U.K., September 11, 2015.

    Speaker, “Legal and Regulatory Issues for Cryptocurrencies and Blockchain Technologies,” Cyrpto757, Virginia Beach, VA, September 3, 2015.

    Speaker, ABA’s Bitcoin and Other Digital Currencies: Emerging Issues in Regulation and Enforcement, Washington, D.C., June 26, 2015.

    Speaker, “Lessons Learned from Recent Law Enforcement Actions in the Crypto, Virtual and Digital Currency Landscape,” ACI’s Crypto, Virtual & Digital Currency Conference, Chicago, IL, June 25, 2015.

    Moderator, “The Interplay Between Prepaid Cards, New Technologies, and Emerging Payment Systems, Including Mobile Wallets, Virtual Currencies, and EMV Cards: Exploring New Opportunities and Overcoming Complicated Regulatory and Compliance Challenges,” ACI’s Prepaid Card Compliance, San Francisco, CA, May 29, 2015.

    Speaker, “Hot Topics in Virtual Currencies: Policy, Regulatory, and Business Issues,” New York State Bar Association’s Global Law Week Conference, New York, NY, May 15, 2015.

    Speaker, “Monetary Policy and Next Generation Currencies – Role of Bitcoin and Cryptocurrencies,” 2nd Annual Crowdfunding USA Forum, Washington, D.C., May 7, 2015.

    Speaker, AML Compliance Bootcamp for Digital Currency, San Francisco, CA, February 26-27, 2015.

    Panelist, “Strategies for Financial Access for Payments Companies,” APEX Expo, Las Vegas, NV, February 24, 2015.

    Panelist, Foreign Affair’s Crypotcurrency Policy Forum, New York, NY, February 12, 2015.

    Speaker, “Global Fraud & AML Issues for Cryptocurrencies–Legal & Regulatory: (Bit)CoinWorld Track,” Money20/20, Las Vegas, NV, November 2, 2014.

    Speaker, “Can eCash & Virtual Currency Compete with Other Electronic Payments?” GACHA Solutions 2014 Conference, Atlanta, GA, September 18, 2014.

    Moderator, “Emergence of Virtual Currency: Myths & Facts of Virtual Currency,” WesPay 14th Annual Payments Symposium, Anaheim, CA, September 15, 2014.

    Speaker, “The Rise and Fall of Digital Currencies (and Rise Again),” McKinsey & Co.’s The Cash Flow Management Forum, Chicago, IL, August 5, 2014.

    Moderator, “Virtual Currencies: GAO’s Review of the Key Regulatory, Law Enforcement, and Consumer Protection Challenges,” Women in Housing & Finance’s Brown Bag Lunch, Washington, D.C., July 22, 2014.

    Speaker, “Finance Section: Bitcoin,” Video Game Bar Association’s International Conference on Game Business and Legal Affairs, Los Angeles, CA, May 19, 2014.

    Speaker, “Community-Based Currency,” Schumacher Center for a New Economics, Great Barrington, MA, May 8, 2014.

    Speaker, “Impact of Technology and Innovation on Regulation, Compliance & Enforcement,” Women in Housing & Finance’s Spring Symposium, Washington, D.C., April 30, 2014.

    Speaker, “Digital Currency,” the National Association of State Credit Union Supervisors Webinar, April 28, 2014.

    Moderator, “Regulatory, Security & Cybercrime,” Mobile Payments & Virtual Currencies conference presented by Columbia Institute for Tele-Information, New York, NY, April 28, 2014.

    Panelist, “Bitcoin: Currency, Commodity, or Con?” Council on Foreign Relations’ Emerging Technology Series, New York, NY, April 22, 2014.

    Panelist, “Cryptocurrency and Global Financial Security,” The Georgetown Diplomacy and International Security Conference, Washington, D.C., April 11, 2014.

    Panelist, “Can e-Cash & Virtual Currency Compete with Other Electronic Payments?” NACHA – The Electronics Payments Association, Orlando, FL, April 8, 2014.

    Panelist, “Bitcoins, Candy Crush and Cold Hard Cash: Virtual Currency and Real World Money in the Virtual World,” ABA Forum on the Entertainment and Sports Industries’ Video Games & Digital Media Conference, San Francisco, CA, March 17, 2014.

    Panelist, "The Evolution Currency," Payments Operations and Technology Forum, Atlanta, GA, November 19, 2013.

    Panelist, "Virtual Currency," Bank Secrecy Act Conference, Orlando, FL, November 2, 2013.

    Panelist, "Math-Based & Virtual Currencies: Legal & Regulatory Frontiers" and "Bleeding-Edge Issues in Domestic & International Leading-Edge Innovation," 2020 Money Conference, Las Vegas, NV, October 6, 2013.

    Moderator, "Federal Regulatory & Enforcement Roundtable: Insights on the Latest Initiatives, Compliance Obligations, and Fraud Risk and Schemes," ACI's 2013 Prepaid Card Compliance Forum, San Francisco, CA, October 3, 2013.

    Panelist, "Developing, Implementing and Maintaining AML & Fraud Deterrence Strategies & Programs for Emerging Payment Systems, Without Negatively Impacting the Customer/User Experience," ACI's Emerging Payment Systems Conference, Washington, D.C., September 19, 2013.

    Panelist, "The Future Role for Non-Traditional Law Enforcement and the Role of the Private Sector," 31st International Symposium on Economic Crime, Cambridge, England, September 7, 2013.

    Participant, "Building Your Profitable Prepaid Business," Network Branded Prepaid Card Association workshop, Washington, D.C., June 26, 2013.

    Panelist, "Bitcoin and Beyond: Financial Privacy and Censorship," 2013 Computers, Freedom and Privacy Conference, Washington, D.C., June 26, 2013.

    Panelist, "Developing, Implementing, and Maintaining AML Programs and Fraud Deterrence Strategies on an International Basis: Assessing the FATF 40 Recommendations, Overcoming Implementation Challenges in a Global Market, and Minimizing Exposure to New and Emerging Fraud Risks," Advanced Forum on International and Cross-Border Payments, November 27, 2012.

    Co-chair, ACI National Advanced Forum on Emerging Payment Systems, Washington, D.C., September 27, 2012.

    Panelist, "A Focus on BSA and AML Regulatory Compliance and Law Enforcement: Developing, Implementing, and Maintaining Fraud Deterrence Strategies for Emerging Payment Systems," ACI National Advanced Forum on Emerging Payment Systems, Washington, D.C., September 27, 2012.

    Speaker, "Economic Crime - Surviving the Fall: Myths and Realities," 30th International Symposium on Economic Crime, September 2, 2012.

    Panelist, "Overcoming Challenges in Online Payments for Regulated iGaming Products," Annual Global iGaming Summit, San Francisco, CA, April 24, 2012.

    Panelist, "Developing, Implementing, and Maintaining AML and Fraud Deterrence Strategies for Emerging Payment Systems," ACI's 3rd Annual Emerging Payment Systems Forum, San Francisco, CA, April 16, 2012.

    Panelist, "A Focus on Prepaid Card Program Partners: Enhancing Compliance Efforts and Facilitating Communication Along the Prepaid Value Chain," ACI's 5th Annual Forum on Prepaid Card Compliance in Washington, D.C., January 30, 2012.