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 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 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


•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


Business Fraud 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

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

•Breuer Cautiously Approaches Costly FCPA Cases
Jul 02, 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

SEC Enforcement Advisor

•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


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Office Information

Raymond Banoun

700 Sixth Street, N.W.
WashingtonDC 20001


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