Peter D. Hardy

Partner
Philadelphia
Washington, DC

Peter Hardy, a former federal prosecutor, is a national thought leader on the subject of money laundering, anti-money laundering and criminal tax law. He co-leads and is the founder of the firm's Anti-Money Laundering Team. Peter edits and frequently contributes to Money Laundering Watch, Ballard Spahr's blog devoted to criminal and regulatory money laundering issues. He is the author of Criminal Tax, Money Laundering, and Bank Secrecy Act Litigation, a well-reviewed and comprehensive legal treatise concerning the investigation, prosecution and defense of criminal tax, money laundering, and Bank Secrecy Act cases, published by Bloomberg BNA. Peter also serves as the Co-Chair for the Practising Law Institute's annual Anti-Money Laundering Program, and serves on the Steering Committee for the Cambridge Forum on Sanctions & AML Compliance.

Peter advises corporations and individuals across a range of industries against allegations of misconduct, including money laundering, tax fraud, mortgage fraud and lending law violations, securities fraud, public corruption, Foreign Corrupt Practices Act violations, and other financial fraud. Peter also counsels financial institutions and businesses on their anti-money laundering obligations under the Bank Secrecy Act and other compliance requirements, including issues involving money transmission, digital assets and cryptocurrency, cannabis and anti-corruption.

Experience 

Representative Matters

  • Conducted numerous corporate internal investigations across a spectrum of industries, including investigations focused on potential BSA/AML, money laundering, tax, other financial fraud and securities violations, prompted by allegations by federal government, private plaintiffs and/or company insiders and would-be whistleblowers. These engagements frequently involve advising on the response to criminal, civil and administrative government subpoenas, investigations and examinations.
  • Advised financial institutions and other companies, including non-bank lenders and real estate industry participants, on technical regulatory compliance with BSA/AML, counter-terrorism financing, and anti-corruption requirements. This work includes the drafting and revising of compliance policies and procedures; developing risk assessments; advising whether a SAR filing(s) is appropriate; conducting AML due diligence during M&A transactions; determining whether to close customer accounts; helping institutions respond to government regulatory examinations, investigations and subpoenas; determining whether a business should register as a money services business or money transmitter; FCPA compliance; and providing BSA/AML advice specific to issues involving cryptocurrency, digital assets and cannabis.
  • Successfully defended major financial institution in multiple complex civil lawsuits alleging that the financial institution violated its own BSA/AML procedures and contributed to misconduct perpetrated by former customers.

Professional Highlights

Judicial Clerkships

The Hon. George E. Woods, U.S. District Court for the Eastern District of Michigan

The Hon. Cornelia G. Kennedy, U.S. Court of Appeals for the Sixth Circuit

Professional Activities

Fellow, American College of Tax Counsel

Co-chair, Practising Law Institute, Anti-Money Laundering Program

American Bar Association Criminal Justice Section, White Collar Crime Committee

Federal Bar Association for the Eastern District of Pennsylvania, Criminal Law Committee

Cambridge Forum on Sanctions & AML Compliance, Steering Committee

Recognition & Accomplishments

Outstanding Attorney Award, Tax Division, U.S. Department of Justice

Chambers USA, Litigation: White-Collar Crime & Government Investigations (Pennsylvania), 2021, 2022

The Best Lawyers in America, tax law, criminal defense: white collar, 2019-2023, corporate compliance law, 2023

Speaking Engagements

Speaker, "The Future of the Bank Secrecy Act: Regulatory Developments and Reform," CFS in Turbulent Times webcast series, December 11, 2020

Speaker, "Future of BSA: Legislative Proposals, Regulatory Developments, and PPP Lending webinar," Credit Union National Association, November 23, 2020

Panelist, "Defenses to Tax Crimes: Attacking Willfulness," IRS Representation Conference, November 20, 2020

Board Memberships & Community Service

Rebuilding Together Philadelphia, Honorary Board Member and Past President of the Board

Esperanza Immigration Legal Services, Board Member

Publications

Co-author, "Whistle in confidence - US Anti-Money Laundering Act 2020," Money Laundering Bulletin, February 1, 2021

Co-author, "U.S. Passes Historic BSA/AML Legislative Change," Money Laundering Watch blog, January 5, 2021

Quoted, "Defense Bill To Usher In New Era For Anti-Money Laundering," Law360, December 10, 2020

Quoted, "FinCEN Files seem unlikely to alter US approach to BSA/AML enforcement," S&P Global Market Intelligence, September 24, 2020

Credentials 

Education

University of Michigan Law School (J.D., cum laude, 1994)
Executive Note Editor, University of Michigan Journal of Law Reform

University of Michigan (B.A. 1991, with highest distinction)
Phi Beta Kappa

Admissions

District of Columbia

Pennsylvania

U.S. District Court for the Eastern District of Pennsylvania

U.S. District Court for the Eastern District of Michigan

U.S. Tax Court

U.S. Court of Appeals for the Third Circuit

U.S. Court of Appeals for the Fourth Circuit