Exploration of Advantages and Disadvantages of Geographic Targeting Orders


Expert Panelists

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Several sectors of the U.S. economy, including real estate and money service businesses, have been at the center of Geographic Targeting Orders (GTOs), under which the government can require financial institutions or non-financial business or professional sectors in a particular geographic area to engage in additional client due diligence, record-keeping and reporting.

Many sectors not otherwise subject to an anti-money laundering (AML) and suspicious activity reports (SAR) filing requirements are vulnerable to being used to launder the proceeds of unlawful activities. International standards promulgated by the Financial Action Task Force (FATF) have been incorporated in domestic law by nearly every country of the world, with banks, broker-dealers, payment agencies and other businesses subject to required preventative measures to prevent and uncover money laundering.

So why are GTOs necessary in the U.S., and what is not fully covered in the current preventative measures to combat the laundering of these proceeds? Should these same preventive measures apply to other sectors, such as title insurance companies, real estate agents, realtors, and lawyers, and if so, why? Are there other, better solutions to be found, such as requiring these businesses and professions to adopt an AML program without regard to geography or a sunset date?

Join our panel of experts for a discussion of these issues.

Introductions and closing remarks

  • Professor Richard Gordon, Director, Financial Integrity Institute, Case Western Reserve University
  • Professor Cathy Lesser Mansfield, Executive Director, Master of Arts in Financial Integrity Program, Case Western Reserve University.


  • Pawneet Abramowski, SVP, Chief Compliance Officer & BSA/AML Officer, Community Federal Savings Bank (Moderator)
  • Ross Delston, Expert Witness, Attorney & Former US banking regulator (FDIC)
  • Alma Angotti, Partner and Co-Head of Global Investigations & Compliance at Guidehouse
  • Braddock Stevenson, Bank Secrecy Act Counsel at O'Melveny & Myers LLP
  • Kelly Dixon, AML Compliance Advisor Lead, USAA


CWRU School of Law Virtual Event

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