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Kyle R. Freeny

Kyle R. Freeny, a skilled trial attorney and former federal prosecutor for the Special Counsel’s Office and the Department of Justice’s Money Laundering and Asset Recovery Section (MLARS), draws on more than a dozen years of high-profile experience in the federal government to help clients navigate sensitive government and internal investigations, criminal and civil enforcement matters, and related complex litigation. She has particular experience in matters involving complex financial crime, cross-border investigations, anti-money laundering, anti-corruption, economic sanctions, asset forfeiture, and affirmative challenges to federal agency action.

While at the Department of Justice, Kyle also played a key role in major international money laundering and corruption matters, including important matters involving the Bank Secrecy Act (BSA) and Foreign Corrupt Practices Act (FCPA). Kyle also has considerable experience handling sensitive and complex cross-border issues in transnational financial cases, and she was responsible for the largest civil asset forfeiture recovery in DOJ history.

Kyle uses this deep experience in federal law enforcement to counsel clients facing scrutiny from DOJ, the Securities and Exchange Commission (SEC), the Financial Crimes Enforcement Network (FinCEN), and other law enforcement and financial regulatory agencies. Kyle conducts internal investigations on a range of issues and advises clients on a wide array of anti-money laundering, anti-corruption, and other compliance issues.

Kyle also helps clients develop and litigate challenges to federal regulations, policies, and agency decisions across a range of industries, drawing on her years of prior experience at DOJ representing a cross-section of federal agencies —from the Office of Foreign Assets Control (OFAC) to the Department of Energy to the Department of State and various intelligence agencies—in high-profile litigation. She has appeared before federal trial courts across the country.

On April 7, 2025, U.S. Deputy Attorney General Todd Blanche issued a memorandum titled “Ending Regulation by Prosecution” (Blanche Memo), outlining a new Department of Justice approach to digital asset enforcement.
Continue Reading Justice Department Issues Memorandum Realigning DOJ’s Crypto Enforcement Efforts

On Nov. 26, 2024, in what has been deemed a win for open-source technology, the U.S. Court of Appeals for the Fifth Circuit reversed the district court’s ruling in Van

Continue Reading Fifth Circuit Rejects OFAC Sanction of Tornado Cash Crypto Code
  1. Continued Robust Litigation and Enforcement Actions by Federal and State Regulators and Enforcement Authorities – We will likely see a similar level of anti-fraud prosecutions by the Department of Justice
Continue Reading 5 Trends to Watch: 2024 Blockchain

On Oct. 23, 2023, FinCEN published an NPRM that identifies international CVC mixing as “a class of transactions of primary money laundering concern,” and finds that imposing additional recordkeeping and

Continue Reading FinCEN Proposes Rule to Address Money Laundering and Terrorist Financing Risks Associated with CVC Mixing

On Aug. 8, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed economic sanctions on Tornado Cash, a popular cryptocurrency mixing service that allows customers to
Continue Reading OFAC Sanctions Cryptocurrency Mixing Service for Allegedly Facilitating Money Laundering

On June 30, 2022, the U.S. Department of Justice (DOJ) announced criminal charges against six defendants in four separate criminal cases involving alleged fraud in the offering of cryptocurrency investment
Continue Reading DOJ Signals Concerted Effort to Prosecute Alleged Cryptocurrency Fraud