Raymond Banoun

Washington,  DC  U.S.A.
Phone202 862 2426

Peer Rating
AV® Preeminent

Client Rating

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Experience & Credentials Ratings & Reviews

Practice Areas

  • Anti-Money Laundering & Asset Forfeiture
  • Business Fraud & White Collar Defense
  • Commercial Bribery & FCPA
  • Corporate Governance
  • Cyber and National Security
  • FCPA and International Anti-Bribery
  • Securities Enforcement & Investigations
  • False Claims Act
  • Financial Regulation
  • Government & Internal Investigations and Defense
  • Litigation
  • OFAC and Export Control
  • SEC Regulated Entities
University City College of New York, B.A., 1965
Law SchoolGeorge Washington University Law School, J.D., with honors, 1968
AdmittedDistrict of Columbia; New York

Raymond Banoun is one of the leading business fraud litigators in the nation. A fellow of the American College of Trial Lawyers who has been named among the top litigators in the country by Lawdragon and recognized by Chambers USA, Legal 500, The Best Lawyers in America, US News and World Report, and other leading publications. He represents corporations and financial institutions, their audit committees, law firms, and executives in all aspects of criminal and civil enforcement matters; defends federal and state investigations, and in litigation, both pre- and post-indictment, including in whistleblower, False Claims Act and RICO actions in all courts. He has served, and serves, as outside compliance counsel to several international companies, and as a monitor as part of a Department of Justice corruption settlement. He regularly conducts compliance audits, formulates compliance programs, and advises with respect to their implementation and related governance issues.

Ray also has represented clients in matters involving the Foreign Corrupt Practices Act, money laundering and asset forfeiture, foreign bank secrecy, data privacy and blocking statutes, the anti-fraud provisions of the securities and commodities statutes, economic sanctions, export control and anti-boycott laws and regulations, criminal tax and antitrust violations, banking, healthcare, government procurement, and bankruptcy fraud. In 2013 he was recognized as an “FCPA Master” by Main Justice for his record of achievement in anti-corruption defense work.

He has represented companies and their executives and audit committees before the U.S. Department of Justice, U.S. Attorneys' Offices throughout the country, the divisions of enforcement of the Securities and Exchange Commission and the Commodity Futures Trading Commission, the Federal Reserve, the FDIC, the Treasury Department's Office of Foreign Assets Control and FinCen, the Internal Revenue Service, the various Inspectors General, Department of Defense suspension and debarment boards, the European Investment Bank, and U.S. Congressional Committees.

He is well-versed in the money laundering laws of the United States and foreign countries, including the USA PATRIOT Act and the Bank Secrecy Act and has co-authored a treatise entitled Money Laundering, Terrorism and Financial Institutions, published by The Civic Research Institute. He has conducted audits of U.S. and foreign financial institutions to ensure compliance with such laws, and devised remedial plans, policies, procedures, and forms to comply with laws and regulations in this area. He is also knowledgeable of foreign secrecy and confidentiality laws, European and other data privacy and blocking statutes, international mutual assistance and tax treaties. His expertise in these areas extends to Switzerland, England, France, Luxembourg, Hong Kong, Bermuda, the Cayman Islands, the Bahamas, Panama, and other European and Caribbean countries.

Prior to joining Cadwalader, he served for 13 years as an Assistant United States Attorney for the District of Columbia, where he headed the Fraud Division, and for three years as a Special Assistant to the United States Attorney for the Central District of California in Los Angeles. He was a partner at the Washington, D.C. firm of Arent, Fox, Kintner, Plotkin & Kahn where he chaired the Business Fraud Group. He also clerked for U.S. District Court Judge Harold H. Greene.

He served as Chairman of the American Bar Association Criminal Justice Section's White Collar Crime Committee, and as Chairman of the Business Crimes Committee of the International Bar Association's Section of Business Law. He is the founder and chair of the highly acclaimed American Bar Association's annual National Institute on White Collar Crime, currently in its twenty-ninth year.

News & Resources


News Releases

Cadwalader advises on Singapore dollar and RMB denominated bond issuances by mainland Chinese companies

Nov 26, 2014

Cadwalader Attorneys, Practices Recognized in 2015 Edition of The Best Lawyers in America

Aug 18, 2014

Cadwalader Recognized Among Leading Firms in The Legal 500 US 2014

Jun 27, 2014

Super Lawyers Recognizes Cadwalader’s Washington, D.C. Attorneys

Apr 25, 2014

Cadwalader Recognized in 2013 Edition of The Legal 500 US

Oct 25, 2013

2014 Edition of The Best Lawyers in America Recognizes 44 Cadwalader Attorneys Across a Range of Practices

Oct 22, 2013

Washington, D.C., Super Lawyers Recognizes 15 Cadwalader Attorneys

May 01, 2013

2013 Edition of The Best Lawyers In America Recognizes 45 Cadwalader Attorneys in Multiple Areas of Practice

Oct 06, 2012

The Legal 500 Recognizes More than 15 Cadwalader Practices and 47 of the Firm’s Lawyers Across U.S. Offices

Jun 06, 2012

2012 Edition of The Best Lawyers In America Recognizes 45 Cadwalader Attorneys in 30 Areas of Practice

Sep 06, 2011

The Legal 500 U.S. Recommends Cadwalader in 13 Areas of Practice and Highly Ranks More Than 50 Attorneys

Jun 01, 2011

Super Lawyers Taps Cadwalader DC Attorneys as Outstanding in Their Fields

May 20, 2011

The Best Lawyers In America Recognizes 37 Cadwalader Attorneys in 21 Areas of Practice

Aug 04, 2010

Cadwalader Practices Commended by US Legal 500

Jun 16, 2010

2010 Edition of The Best Lawyers In America Recognizes Numerous Cadwalader Attorneys

Aug 07, 2009

Cadwalader Moves to 700 Sixth in D.C.’s Penn Quarter

Jul 06, 2009

Cadwalader Lauded in Multiple Practices in Chambers USA

Jun 12, 2009

Recent Press

World Recognition of Distinguished General Counsel

Jun 02, 2011

Federal Sentencing Commission Modifies Sentencing Guidelines Pertaining to Organizations

Apr 20, 2010


Cadwalader Attorneys, Practices Recognized in 2015 Edition of The Best Lawyers in America

Aug 18, 2014

Cadwalader Recognized Among Leading Firms in The Legal 500 US 2014

Jun 27, 2014

Super Lawyers Recognizes Cadwalader’s Washington, D.C. Attorneys

Apr 25, 2014

Cadwalader Recognized in 2013 Edition of The Legal 500 US

Oct 25, 2013

2014 Edition of The Best Lawyers in America Recognizes 44 Cadwalader Attorneys Across a Range of Practices

Oct 22, 2013

Chambers and Partners USA 2013

May 24, 2013

Super Lawyers Recognizes 15 Cadwalader Attorneys in Washington, D.C.

May 01, 2013

Raymond Banoun and Peter Clark Recognized as FCPA Masters by Main Justice

Apr 24, 2013

Super Lawyers 2012

Oct 15, 2012

The Best Lawyers In America 2013

Oct 06, 2012

Chambers and Partners USA 2012

Jun 07, 2012

2012 Legal 500 US

Jun 06, 2012


Clients & Friends Memos

The Bribery Act 2010: Are You Ready?

Jun 30, 2011

SEC Launches FCPA Probe of Financial Services Industry’s Interactions with Sovereign Wealth Funds

Mar 18, 2011

Foreign Bank and Financial Account Reporting

Aug 14, 2009

FBAR Filing Requirements For Owners of Foreign Accounts, Hedge Fund Investors, Hedge Fund Managers, and Financial Institutions; June 30, 2009 Filing Deadline Extended Until September 23, 2009 For Certain Filers

Jun 29, 2009

IRS Offers to Ease Penalties for Taxpayers Who Disclose Their Overseas Accounts in the Wake of the Department of Justice’s Continuing Crackdown on the Use of Tax Havens

Apr 14, 2009


Money Laundering, Terrorism and Financial Institutions

Money Laundering, Terrorism and Financial Institutions, co-authored by Raymond Banoun, covers terrorism, money laundering, and the USA PATRIOT Act


White Collar Crime, 2011 - A Year in Review

Jun 01, 2012

World Recognition of Distinguished General Counsel

Jun 02, 2011

White Collar Crime, 2010 - A Year in Review

May 16, 2011

Honest Services Fraud in the Private Sector

Mar 01, 2010

World Bank reveals companies debarred under corporate procurement program

Mar 13, 2009


31st International Conference on the Foreign Corrupt Practices Act

Nov 17, 2014

ABA Criminal Justice Section Southeastern White Collar Crime Institute

Sep 11, 2014

Annual New York Conference on the Foreign Corrupt Practices Act

May 19, 2014

The Evolving Regulatory Environment for Virtual Currencies

May 08, 2014

The American Bar Association's 28th Annual National Institute on White Collar Crime

Mar 05, 2014

30th National Conference On The Foreign Corrupt Practices Act

Nov 18, 2013

Securities Enforcement Forum 2013

Oct 09, 2013

2nd Annual International White Collar Crime & International Investigations Conference

Oct 07, 2013

ABA White Collar Crime Institute 2014

Mar 06, 2013

28th National Conference on the Foreign Corrupt Practices Act

Nov 15, 2012

Annual Money Laundering Enforcement Conference

Nov 11, 2012

Investing in China: QFII, QDLP, Direct Investment, Compliance, and Exits

Oct 15, 2012

ABA First Annual White Collar

Oct 07, 2012


FCPA Advisor

Eleventh Circuit Defines “Instrumentality” Broadly Under the FCPA

May 19, 2014

Will Independent Directors Be on the Hook for Failure of Internal Controls in FCPA Cases?

Jul 15, 2013

Allianz To Pay $12.3M To Settle SEC’s Bribery Allegations

Dec 19, 2012

DOJ and SEC Issue FCPA Guidance

Nov 19, 2012

FCPA Allegations Involving Customs Clearance in Kazakhstan

Jun 11, 2012

Lindsey Manufacturing's Conviction Overturned

Dec 05, 2011

With Publication of Final Guidance, UK Bribery Act to Go Into Effect on July 1, 2011

Apr 15, 2011

U.K. Ministry of Justice Further Delays Implementation of Bribery Act

Feb 03, 2011

New Compliance Criteria Set in Sentencing Guidelines

Nov 30, 2010

ABB Entities Resolve FCPA Investigation

Nov 30, 2010

Panalpina, Shell, Four Oil Services Companies Settle FCPA Charges

Nov 30, 2010

Intermediaries Indicted for Involvement in Scheme to Bribe Mexican Officials

Sep 29, 2010

U.K. Ministry of Justice Releases Guidance on Bribery Act

Sep 29, 2010

Department of Justice Issues FCPA Opinion Procedure Release on the Definition of the term “Foreign Official”

Sep 03, 2010

Alliance One and Universal Corp Settle DOJ, SEC Charges; Former Country Manager of Alliance One Pleads Guilty

Aug 16, 2010

Giffen Pleads Guilty to Misdemeanor Tax Violation 7 Years After FCPA-Indictment; His Merchant Bank Pleads Guilty to FCPA Felony

Aug 16, 2010

Department of Justice Issues Second FCPA Opinion Procedure Release for 2010 Regarding Government Compelled Grants and Due Diligence

Aug 02, 2010

GE Agrees to Pay $23.4 Million to SEC to Settle FCPA Charges

Jul 29, 2010

Implementation of U.K. Bribery Act Delayed Until April 2011

Jul 26, 2010

ENI and Snamprogetti Settle Criminal and Civil Charges Related to the Bonny Island Project in Nigeria; JGC Corporation Discloses Settlement Discussions

Jul 15, 2010

Financial Reform Bill Compensates Whistleblowers Assisting the SEC

Jul 02, 2010

Technip Enters into DPA with DOJ, Pays $338 Million Settlement

Jul 02, 2010

First DOJ FCPA Opinion Procedure Release in 2010

Jul 02, 2010

Department of Justice Guidance on Company Disputes with Corporate Monitors

Jul 02, 2010

Breuer Cautiously Approaches Costly FCPA Cases

Jul 02, 2010

SEC Enforcement Advisor

SEC Announces Largest Ever Whistleblower Award, Awards $30 Million to Foreign Whistleblower

Oct 01, 2014

Second Circuit Holds that Anti-Retaliation Provisions of Dodd Frank Act Have No Extraterritorial Application

Aug 20, 2014

Gatekeepers In the Enforcement Spotlight

May 22, 2014

SEC Announces Second Set of Whistleblower Awards

Jul 01, 2013

The SEC's New Policy on Seeking Admissions in Settlements

Jun 28, 2013

White Collar Defense and Investigations Advisor

AML Guidance Issued for Banks Seeking to Service Marijuana-Related Businesses

Feb 27, 2014

SEC Issues Guidance on Conflict Minerals Rule

Jun 10, 2013

U.S. and Chinese Regulators Sign Historic Memorandum of Understanding Regarding Enforcement Cooperation

May 31, 2013

Southern District of New York Orders Chevron CEO and General Counsel to Testify in RICO Suit Related to $18 Billion Ecuadorian Judgment

May 28, 2013

European Union Pending Legislation Requiring Additional Transparency from Extractive Industries

May 20, 2013

A Brief Primer for Corporate Social Media Disclosures in Light of the SEC’s Recent Guidance on Regulation FD

Apr 08, 2013

The Dodd-Frank Whistleblower Program: An Analysis of the SEC’s Second Annual Report, Best Practices for Dealing with Whistleblowers, and Recent Cases Interpreting the Scope of the Anti-Retaliation Provisions of the Dodd-Frank Act

Dec 10, 2012

SEC Issues Resource Extraction Rule

Sep 21, 2012

SEC Issues Conflict Minerals Rule

Aug 29, 2012

The Evolving Obligations of Public Companies to Disclose Cyber-Intrusions

Jul 09, 2012

Justice Department Establishes Residential Mortgage-Backed Securities Working Group

Jan 31, 2012

The Dodd-Frank Whistleblower Provisions: Considerations for Effectively Preparing for and Responding to Whistleblowers

May 26, 2011

FinCEN Issues Final Rule on Foreign Bank Account Reporting (FBAR)

Mar 01, 2011

European Court of Justice Declares Corporate Communications With In-House Counsel Not Protected by Legal Professional Privilege

Sep 17, 2010

Barclays Bank PLC Forfeits $298 Million for Violations of U.S. Economic Sanctions; U.S. Judge Questions Use of DPA, Lack of Individuals Prosecuted

Aug 19, 2010

The Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010

Jul 26, 2010

New Whistleblower Compensation Enacted for Securities and FCPA Disclosures

Jul 26, 2010

SEC and Goldman Sachs Agree to Settle Historic Market-Crisis Enforcement Action

Jul 19, 2010

Supreme Court Limits Application of the Honest Services Fraud Statute

Jul 15, 2010


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Office Information

Raymond Banoun

700 Sixth Street, N.W.
WashingtonDC 20001


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