Alert 02.13.25
Carolina A. Fornos, the head of Pillsbury’s New York Litigation group and the leader of its Latin America practice, is a former federal prosecutor and experienced trial attorney whose practice focuses on international commercial disputes, civil and criminal enforcement matters, and cross-border internal investigations and compliance.
Carolina has extensive experience in all phases of federal investigations and litigation. As a former federal prosecutor in the Southern District of New York, in both the civil and criminal divisions, she spent almost nine years handling a wide range of matters ranging from False Claims Act cases and health care fraud to bribery, bank fraud, tax fraud and money laundering violations. As a member of the Money Laundering and Asset Forfeiture Unit, Carolina investigated money laundering crimes and potential violations of the Bank Secrecy Act.
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Building on her extensive government experience, Carolina’s practice at Pillsbury focuses on three areas: First, she provides informed and practical advice to corporations with respect to creating, refining and adhering to compliance programs. Second, Carolina guides her clients through the challenges of internal investigations with an eye towards efficiently assessing risk and, where needed, taking corrective measures. Third, Carolina represents clients in complex commercial litigations that often involve alleged commercial malfeasance, such as bribery or fraud. Fluent in Spanish, Carolina’s practice also serves Latin American clients in all the above areas.
Representative Experience
- Assisted foreign banks and other companies with improving compliance with U.S. laws and regulations.
- Advised foreign companies on FCPA compliance and best practices.
- Assisted an American utility company with an internal investigation into cybersecurity issues and related matters.
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- Cross-Border Litigation
- Representing several leading financial institutions in the Middle East alleged to have violated the Anti-Terrorism Act and Justice Against Sponsors of Terrorism Act.
- Representing Bombardier and its related affiliates in adversary proceedings brought by the chapter 7 trustee of an international air charter operator that filed for bankruptcy and is now seeking to claw back over $450 million from various entities.
- Defending a Mexican client in a breach of contract suit regarding a software product.
- FCPA, Anti-Money Laundering, Bank Secrecy Act and Asset Forfeiture Investigations and Litigation
- Representing former banking executives in a grand jury investigation related to potential violations of AML regulations.
- Representing an international company in DOJ and SEC investigation regarding alleged money laundering, fraud (bank fraud, wire fraud and securities fraud), and violations of the registration provisions of the securities laws.
- Representing multiple bank executives in connection with allegations of AML/BSA violations.
- Representing an international fintech company as lead counsel in an internal investigation and in government inquiries related to allegations of insider trading, fraud, money laundering and HR-related violations, with witnesses and documents located abroad.
- Advised several financial institutions and bank employees in connection with U.S. government investigations related to the Panama Papers leak.
- Advised foreign companies on FCPA compliance.
- As a prosecutor, worked with numerous federal agencies to investigate money laundering and potential violations of the Bank Secrecy Act by financial institutions whose AML procedures failed to identify risk patterns associated with potential criminal activity.
- Commercial Litigation
- Successfully represented financial institution at trial in connection with multiple breach of contract actions involving real estate portfolio.
- Handled a nationwide products liability class action involving allegations of defective plumbing products, defeating class certification.
- Defended cannabis company in commercial disputes.
Professional Highlights
- Served in the Office of the White House Counsel vetting candidates for presidential appointments (2010 – 2011).
- Frequent contributor to a variety of publications on topics involving white collar defense, AML and regulatory enforcement issues.
- Recognized by The Legal 500 U.S. in Corporate Investigations & White-Collar Criminal Defense (2017 – 2019).
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- Honors & Awards
- Recognized by Latinvex as one of the Top 100 Female Lawyers with a focus on Latin America (2021 – 2023).
- Profiled as a key member of Pillsbury’s Latin Lawyer 250-ranked practice in the region.
- Associations
- The Federal Bar Council Inn of Court
- New York City Bar Association
- Hispanic National Bar Association
- Speaking Engagements
- “FinCEN Geographic Targeting Orders (GTOs) Connected to Real Estate Purchases,” ACAMS Webinar, April 25, 2018.
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“Analyzing Global Risks of Money Laundering through Real Estate,” ACAMS Webinar, April 12, 2017.
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Pillsbury Winthrop Shaw Pittman Annual MCLE Marathon, New York, “White Collar Enforcement Trends for 2017,” March 22, 2017.
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“Mexican National Anticorruption System” and “Financial Crimes and AML,” Deloitte’s Financial Crimes Summit 2017, Mexico City, March 16, 2017.
- “Conducting FCPA Internal Investigations: How to Stay on the Government’s Good Side,” Duxes’ American Anti-Corruption Compliance Summit 2016, New York, October 24, 2016.
- “Preliminary Remedies, Preparing Discovery Demands and Discovery Responses, and Summary Judgment Motions,” Practicing Law Institute’s Pretrial Practice 2016, New York, May 6, 2016.
- “Data Breach Insurance: What to Seek from D&O and Cyber Insurance Policies,” Hispanic National Bar Association’s 2016 Corporate Counsel Conference & Moot Court Competition, Las Vegas, March 17, 2016.
- “Anti-Money Laundering Enforcement: Developments Affecting the Real Estate Industry,” Pillsbury Winthrop Shaw Pittman and Engel & Völkers, New York, February 18, 2016.
- “Brazil and the United States: Anti-Bribery and Anti-Money Laundering Enforcement Developments,” Pillsbury Winthrop Shaw Pittman, New York, October 22, 2015.
- “AML Compliance: Keep the Bulls-Eye off Your Industry,” Association of Corporate Counsel, New York, September 17, 2015.
- “Effective Trial Techniques: Telling Your Client’s Story through Cross-Examination,” Hispanic National Bar Association Annual Convention, Boston, September 3, 2015.
- External Publications
- “Cyberattacks are the New Norm: How to Respond and Get Insurance Recovery for Government Investigations,” Pratt’s Privacy & Cybersecurity Law Report, Authors: Joseph D. Jean, Carolina A. Fornos, Brian E. Finch, November 2017.
- “Correspondent Banking: A Gateway to Money Laundering Requires Heightened Scrutiny,” New York Law Journal, Authors: Carolina A. Fornos, Katherine A. Lemire, September 26, 2016.
- The Long Arm of the Law: Responding to the Expanding Extraterritorial Reach of the Department of Justice, Inside the Minds: International White Collar Enforcement, 2016 edition, Authors: Marc H. Axelbaum, Carolina A. Fornos, 07/20/2016.
- Using Criminal and Civil Forfeiture to Combat Terrorism and Terrorist Financing, U.S. Attorneys’ Bulletin, Authors: Carolina A. Fornos, Sharon Cohen Levin, 09/01/2014.
- Firm Publications
- DOJ Announces Civil Cyber-Fraud Initiative to Combat Cybersecurity Threats, Authors: Carolina A. Fornos, Meghan D. Doherty, Brian E. Finch, Robert Starling, Ariella Cassell, Ariella Cassell, 10/25/2021.
- Legislative Reform Will Reinvent the U.S. Anti-Money Laundering Regulatory Landscape, Authors: Carolina A. Fornos, Craig J. Saperstein, Aaron R. Hutman, Cassie Lentchner, Zachary M. Kessler, 01/05/2021.
- Compliance Programs Must Track and Adapt to Changes and Risks, Authors: Maria T. Galeno, Mark R. Hellerer, Carolina A. Fornos, Adam Marcu, 06/11/2020.
- Los programas de cumplimiento deben rastrear y adaptarse a cambios y a riesgos, Authors: Maria T. Galeno, Mark R. Hellerer, Carolina A. Fornos, Adam Marcu, 06/11/2020.
- Sellers Beware: The Blurry Line between Profit and Price Gouging under the Defense Production Act, Authors: Mark R. Hellerer, Carolina A. Fornos, Colin Davis, 05/11/2020.
- Time to Update Corporate Compliance Programs Following DOJ Guidance, Authors: Maria T. Galeno, Mark R. Hellerer, Carolina A. Fornos, Adam Marcu, 05/13/2019.
- Hora de actualizar programas de cumplimiento corporativo tras pautas del DOJ Las empresas ahora deben abordar tres preguntas de manera proactiva., Authors: Maria T. Galeno, Mark R. Hellerer, Carolina A. Fornos, Adam Marcu, 05/13/2019.
- DOJ Modifies White Collar Policy Targeting Individuals, Authors: Mark R. Hellerer, Carolina A. Fornos, Brian L. Beckerman, 11/30/2018.
- Cyberattacks Are the New Norm, Authors: Carolina A. Fornos, Joseph D. Jean, Brian E. Finch, 09/21/2017.
- FinCEN Expands Scope of “All Cash” GTOs, Authors: Christine A. Scheuneman, Mark R. Hellerer, Carolina A. Fornos, Amanda Senske, 08/19/2016.
- New Age of Transparency: U.S. Announces Customer Due Diligence Requirements and Other Key Initiatives, Authors: Carolina A. Fornos, Aaron R. Hutman, Amanda Senske, 05/17/2016.
- When Attorneys General Attack: Cybersecurity Investigations and Related Insurance Coverage Issues, Authors: Carolina A. Fornos, Sheila McCafferty Harvey, Joseph D. Jean, Brian E. Finch, 05/04/2016.
- When Attorneys General Attack: AGs’ Aggressive Investigation of Climate Change Disclosures, and Getting Your Insurer to Provide Coverage, Authors: Carolina A. Fornos, Sheila McCafferty Harvey, Joseph D. Jean, 04/25/2016.
- New FCPA Self-Reporting Pilot Program Formalizes Rewards but Relies on Discretionary Implementation, Authors: Maria T. Galeno, Mark R. Hellerer, Carolina A. Fornos, Thomas C. Hill, William M. Sullivan, Jr., Fabio Leonardi, 04/14/2016.
- The “Panama Papers” and the Secret World of Shell Corporations, Authors: Maria T. Galeno, Mark R. Hellerer, Carolina A. Fornos, Nora E. Burke, William M. Sullivan, Jr., Joseph D. Jean, Alexander D. Hardiman, Danielle Vrabie, Nancy A. Fischer, Matthew F. Putorti, 04/08/2016.
- FinCEN Targets “All Cash” Real Estate Deals in Manhattan and Miami, Authors: Christine A. Scheuneman, Maria T. Galeno, Mark R. Hellerer, Carolina A. Fornos, Caroline A. Harcourt, Amanda Senske, 01/15/2016.
- DOJ’s New White Collar Policy Directs Prosecutors to Focus on Individual Accountability, Authors: Maria T. Galeno, Aaron S. Dyer, Marc H. Axelbaum, Mark R. Hellerer, Carolina A. Fornos, Thomas C. Hill, William M. Sullivan, Jr., Fabio Leonardi, 09/18/2015.
Education
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J.D., Loyola University School of Law, New Orleans, 2000
Member of Loyola Law Review and National Moot Court TeamM.A., Political Science, Louisiana State University, 1996
B.A., Political Science, Louisiana State University, 1994
B.A., French Literature, Louisiana State University, 1994
Admissions
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New York
Courts
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U.S. Supreme Court
U.S. Court of Appeals for the Second Circuit
U.S. District Court for the Southern District of New York
U.S. District Court for the Eastern District of New York
Languages
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Spanish