Law & Advisory Boutique Dedicated to Civil Society & Emergent Technology
Through years of public service and private industry, we have been dedicated to rule of law and personal sovereignty. Our dedication is based on the principles of a free society safe from exploitation and harm – whether at the hands of state or private sector actors. We are a bulwark against overreaching and exploitative behaviors.
Arktouros means “Guardian/Watcher of the Bear,” from Ancient Greek. The brightest star in the northern hemisphere, aside Ursa Major (the Great Bear). Also called the “night-watcher,” revolving about the northern pole, seeming never to set.
Civil Society traces to Aristotle’s koinōnía politike, valuing broad eudaimonia (flourishing) through personal sovereignty, opportunity & democratic rule of law.
Wide variety of clientele from cutting edge cryptographic startups to top-three financial services firms.
Leveraging our significant in-house and government experience we provide practical advice that works in the real world and is designed to navigate an uncertain and evolving regulatory landscape.
Services
Our lawyers are recognized leaders in financial integrity matters, including U.S. economic sanctions compliance and legal challenges to U.S. sanctions actions, anti-money laundering (AML), anti-corruption, asset recovery and forfeiture, and complex cross-border investigations and enforcement. We regularly provide risk management and compliance counseling, crisis management, policy guidance, and criminal and regulatory defense to the DeFi and the crypto community, individuals facing government scrutiny, and financial services organizations. We also advise governments on FATF-related matters, including helping governments prepare for FATF evaluations and assessing compliance with FATF guidelines.
Regulatory & Incident Response
Global advisors solving high-profile regulatory, crisis, enforcement, and related matters including data breach and security incident response. Tailored guidance in AML, sanctions, and state money transmitter laws, focusing on crypto, blockchain, ecommerce, and fintech sectors, along with investment funds and traditional financial services organizations.
Litigation &
Appeals
Experienced trial and appellate counsel that have argued cases at every level of the state and federal court systems, including the US Supreme Court. Develop litigation strategy, lead motions practice and trial, and handle appeals and amicus support. Our expertise helps anticipate and mitigate legal risk in and out of court.
Government Investigations & Criminal Defense
Expert defense in white collar criminal matters and civil investigations, including international money laundering, corruption, sanctions enforcement, fraud, consumer protection, and data protection/privacy. Our team represents and advises individuals and corporations in high-stakes situations around the world.
Corporate Governance & Whistleblower Support
Advisory on corporate governance practices, whistleblower case handling, and creating ethical, transparent corporate environments. Our expertise covers the full spectrum from policy formulation to issue resolution.
Financial Technologies & Payment Systems
Counseling on innovative payment solutions, including credit cards, digital wallets, and crypto/fiat transactions. We assist with legal and regulatory aspects of fintech, ensuring your services are ahead of the curve.
Emerging Technologies & Digital Assets
Legal and regulatory advice for businesses dealing with tokenomics, digital assets, and video game payments. Our forward-thinking approach addresses the unique challenges of the digital age, ensuring your innovation remains compliant.
U.S. Sanctions & International Expansion
Support in navigating U.S. sanctions, including removal petitions and litigation, along with complex sanctions compliance advice and guiding overseas expansion efforts.
Our Team
Our team features leading experts in financial integrity, economic sanctions and the intersection of law with emergent technology – combining hands-on experience as lead in-house lawyers with backgrounds from the Department of Justice, Treasury (OFAC and FinCEN), and top law firms.
Claiborne W. Porter
Partner
Claiborne (Clay) W. Porter is a co-founder of Arktouros PLLC. Clay previously served as the Chief Legal Officer of a technology company providing risk management tools to web3. Clay was a partner at a leading international law firm where he specialized in financial crimes compliance and defense, with a focus on cryptocurrency, payments systems, decentralized finance, and FATF compliance. Clay was also a consultant at a leading international consulting firm where he designed and reviewed AML and economic sanctions compliance programs for cryptocurrency exchangers and payment services companies. Clay has extensive experience conducting anti-money laundering and U.S. economic sanctions risk assessments and compliance reviews, including risk assessments for cryptocurrency exchanges, brokers-dealers, and money services businesses. Clay’s practice includes assisting countries prepare for FATF reviews.
Prior to his move to the private sector, Clay held a number of supervisory roles in the United States Department of Justice's Money Laundering and Asset Recovery Section ("MLARS"), including Acting Principal Deputy Chief of MLARS and Chief of the Bank Integrity Unit. In those roles, Clay supervised complex international investigations and prosecutions (AML, sanctions, and corruption-related prosecutions) of financial services companies, assisted DOJ and interagency policymakers in developing legislative, regulatory, and policy initiatives to combat global illicit finance, and supervised the DOJ's efforts to find and return forfeited criminal proceeds to victims of crime. Clay often worked closely with foreign law enforcement and regulators. Prior to his federal government service, Clay was an associate with two international law firms in New York City and an Assistant District Attorney in Brooklyn, New York, where he prosecuted violent crime.
Michael Mosier
Partner
Michael Mosier is a co-founder of Arktouros PLLC. He has twice been the first in-house counsel at emergent technology companies: Chainalysis (blockchain analytics/investigations) and Espresso Systems (configurable private computation and decentralized sequencing). He has served as an independent board director and chair of the Government Security Committee for an artificial intelligence and autonomous vehicle systems public company operating under a Committee on Foreign Investment in the United States (CFIUS) National Security Agreement.
In public service, Michael was Acting Director, Deputy Director, and the first Digital Innovation Officer of the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN), where he worked closely with federal, state, and international counterparts on the development and implementation of policy and regulation, as well as advancing digital identity and privacy-enhancing technology approaches to preventing exploitation. He also was Counselor (Cybersecurity & Emerging Technology) to the Deputy Secretary of the Treasury.
Previously, Michael served as Associate Director and Acting Deputy Director of Treasury’s Office of Foreign Assets Control (OFAC), leading the Office of Compliance & Enforcement and Office of Sanctions Policy & Implementation.
Before Treasury, Michael was a Deputy Chief in the Department of Justice’s Money Laundering Section, where he created and led the Special Financial Investigations Unit. He also served at the White House National Security Council as Director for Transnational Organized Crime.
Michael has been an adjunct professor (Advanced Evidence for Trial) at Georgetown University Law Center and began his public service as a prosecutor with the Manhattan District Attorney’s Office.
Michael is also a partner in ex/ante, an early-stage venture fund investing in technology that advances democratic resilience and personal sovereignty.
Sydney Abualy
Director of Compliance Advisory
Sydney Abualy is Director of Compliance Advisory at Arktouros PLLC. Sydney specializes in regulatory strategy, state and federal compliance, and anti-money laundering/sanctions risk management in the digital assets and money service business sectors. She has conducted economic sanctions due diligence and compliance reviews for both emerging and established businesses in financial services and has assisted a leading blockchain software company building infrastructure for decentralized technologies in its litigation department.
Prior, Sydney worked in-house as a Legal and Regulatory Analyst at a global payments company where she supported the general counsel with all legal, governance, and policy functions, including working cross-functionally with compliance, finance, product, and engineering teams concerning state money transmission and securities law analysis and interpretation relevant to new product initiatives and partnerships.
She also led operations at a decentralized finance advocacy fund for “builder-first” regulatory initiatives, and served as a Legal Working Group Associate at a leading blockchain trade association where she facilitated discussions on industry developments among corporate attorneys and contributed to policy driven thought-leadership.
Sydney has been published in the Practising Law Institute: The Future of Blockchain and Digital Assets 2021, Brooklyn Journal of Corporate, Financial & Commercial Law, and has served as a panelist for the American Bar Association, Corporate Governance Committee on Legal Governance of Autonomous Organizations.
Sydney is passionate about advancing practical and effective reputational/regulatory risk management in the emerging technologies sector, ensuring they are supported by sound policy and governance.
Sydney earned her Juris Doctor from Brooklyn Law School.
Kenneth A. Blanco
Partner
Regulatory Innovator | Risk/Compliance Leader | Global Executive | Attorney/Trusted Counselor/Advisor
Kenneth A. Blanco (Ken) is a recognized industry leader and speaker in the areas of law, financial integrity and compliance, international governmental relations, and leadership/management dynamics. As an experienced trial attorney, regulator, and compliance officer, Ken has held senior leadership and managerial roles in both the private and public sectors while leading and managing large and diverse global organizations. Ken has served, worked with, and advised numerous U.S. Attorneys General and other Cabinet and Sub-Cabinet members of the United States government, including White House Officials, the National Security Council, the Secretary of the Treasury, as well as boards of directors and senior executives of various public and privately held companies. Ken has worked with, advised, and collaborated with Presidents, Vice Presidents, Supreme Court Justices, Ministers of Finance, and other high-ranking government officials and business leaders from around the world. He has testified before Congress numerous times and has briefed congressional staffers on many occasions regarding important legal, regulatory, and financial issues and topics. He has held the highest security clearances in the U.S. government, and although no longer a government official Ken still holds a Top Secret SCI. He has led teams, worked in, and served as a civilian in war zones and terrorist occupied areas on behalf of the United States government.
Ken is a partner at Arktouros PLLC, an American law and advisory boutique specializing in risk management, emergent technology, and civil society. Prior to joining Arktouros, Ken served as the Chief Compliance Officer (CCO) for Citigroup’s Global Financial Crimes Program, and as a member of Citi’s Independent Compliance Risk Management (ICRM) Executive Management Team, where Ken led and managed a global organization of several thousand compliance professionals in 97 countries around the world. In this role, Ken helped support and protect Citi, and the U.S. financial system, against financial crimes risks by overseeing the firm’s Anti-Money Laundering (AML), Global Financial Crimes Investigations and Intelligence, Sanctions, and Anti-Bribery & Corruption programs, across all lines of business, subsidiaries, and jurisdictions in which Citi operates.
Prior to joining Citi in April 2021, Ken served as the Director of the Financial Crimes Enforcement Network (FinCEN), a Bureau within the U. S. Department of the Treasury, where he worked to combat domestic and international financial crime and enforce and promulgate regulations to protect the United States’ financial system and national security against money laundering and its related crimes, including terrorism financing.
Prior to his appointment as FinCEN Director by the Secretary of the Treasury in 2017, Ken served as the Acting Assistant Attorney General for the Criminal Division at the United States Department of Justice, and for 11 years as a Deputy Assistant Attorney General in the Criminal Division. In these roles, Ken led and was responsible for national and international criminal matters relating to U.S. law, including Bank Integrity, Fraud, FCPA, Money Laundering, Asset Forfeiture, Kleptocracy, and Public Corruption.
After graduating from Georgetown University Law Center in 1989, Ken returned to his native Miami and began his career at the Miami-Dade State Attorney’s Office, where he served as a trial lawyer in various sections including the Organized Crime Section, Public Corruption Section, and the Major Narcotics Section. In 1998, Ken joined the United States Attorney’s Office in the Southern District of Florida (Miami) as an Assistant United States Attorney, where he served in numerous leadership positions including Deputy Chief of Narcotics/Chief of the High Intensity Drug Trafficking Area, Acting Chief of Narcotics, and Deputy Chief of the Major Crimes Section.
During his time at the United States Attorney’s Office, Ken was detailed to Washington, D.C. in 2002 for two years where he served as General Counsel to the 94 United States Attorney’s Offices and the Executive Office of United States Attorneys. In 2006, Ken returned to Washington, D.C. to serve as the Chief of the Narcotic and Dangerous Drug Section at the Department of Justice. He was later promoted to the position of Deputy Assistant Attorney General, where he supervised the Asset Forfeiture and Money Laundering Section, Organized Crime and Gang Section, Child Exploitation and Obscenity Section, Narcotic and Dangerous Drug Section, and matters relating to Afghanistan, Argentina, Colombia, Mexico, and Panama.
Brad Brooks-Rubin
Partner
Brad Brooks-Rubin focuses on the intersection of different types of risks – sanctions, corruption, money laundering, political, human rights – across a range of sectors and geographies and then identifies tangible, practical, and creative solutions. For more than 20 years, in roles across the private sector, government, and civil society, Brad has proved uniquely skilled at developing and implementing comprehensive and proactive strategies to address complex issues.
Brad has a track record of concrete action, from spearheading the innovative G7 initiative to restrict Russian diamonds through supply chain traceability, issuance of numerous sanctions actions and multiple business risk advisories by the U.S. government, unique termination and transition of the Zimbabwe Sanctions Program, and the creation of the Public Private Alliance for Responsible Minerals Trade and innovative “banking roundtables” where compliance analysts could receive critical risk-related information from civil society. Through his unique breadth of experience, Brad understands how companies and other actors can take action to address risks on multiple levels and to respond to varying stakeholder interests and expectations when issues arise.
Most recently, Brad was a Senior Advisor in the Office of Sanctions Coordination at the U.S. Department of State, where he was responsible for sanctions policy coordination related to sub-Saharan Africa, Burma, the West Bank, and natural resources, principally diamonds, gold, and timber. Brad re-joined State from 6.5 years as Policy Director and then Managing Director at The Sentry, an innovative civil society organization focused on the investigating and disrupting the intersection of conflict and corruption. Brad also served as the Strategic Advisor & North America Engagement Lead at the Responsible Jewellery Council in 2021-2022.
Prior to The Sentry and RJC, Brad held roles at the Gemological Institute of America (where he focused on a range of projects related to sustainable development, human rights, and compliance), the U.S. Department of State (where he focused on the Kimberley Process and conflict minerals in eastern DRC, as well as a range of sanctions issues), the Department of the Treasury (where he served as an Attorney-Advisor for the Office of Chief Counsel, Foreign Assets Control, and concentrated on sanctions issues, principally related to a range of sub-Saharan African conflicts), as well as two law firms (where he advised clients on economic sanctions, export controls, and a range of business/human rights issues).
Brad speaks frequently at events on sanctions and natural resources-related policy and compliance conferences and has published extensively in a range of outlets around the world. Brad is an active member of the community in Washington, DC and beyond, serving as an Adjunct Professor at Georgetown University’s School of Foreign Service, Board Member of both the Wildlife Justice Commission and We Are Family DC, DJ on WOWD-LP, co-creator of the 3albums6oldguys substack, and a youth basketball coach.
Michelle Ann Gitlitz
Of Counsel
Michelle Ann Gitlitz is Of Counsel at Arktouros PLLC. Michelle specializes in financial crimes compliance and defense, with a focus on cryptocurrency, payments systems, and decentralized finance. She has designed and reviewed state and federal AML and cybersecurity compliance programs for financial institutions, cryptocurrency exchangers, and payment services companies. She also assists companies in applying for state money transmission licenses and with day-to-day compliance for license holders. Michelle is a frequent speaker, writer, and collaborator with federal and state regulators and legislators on money transmission and payments issues.
Michelle is the author of Reimagining Payments: The Business Case for Digital Currencies (Racquet Publishing 2023) (available on Amazon). The book imparts strategic and tactical advice for senior business leaders on the benefits of digital currency payments and the future of commerce. Michelle has served as a New York State court-appointed fiduciary receiver in the case NYAG v. Coinseed (Index No. 450366/2021) with special powers to locate and safeguard investments made in a defunct cryptocurrency platform.
Michelle previously served as general counsel and corporate secretary of a global payments company, was the co-head of the financial services practice group of an AmLaw 100 law firm, and was the global head of the blockchain and digital asset practice groups at two AmLaw 100 law firms.
Jane Khodarkovsky
Partner
Jane Khodarkovsky was General Counsel and Head of Risk & Compliance at Celo Foundation, which was founded to support the growth and development of the decentralized, open-source, mobile-first Celo platform to help build a regenerative financial system. Jane oversaw all aspects of legal, regulatory and compliance, focusing on decentralized finance (DeFi), decentralized autonomous organizations (DAOs), anti-money laundering, sanctions, securities, and corporate law in the digital technology space in the United States and abroad.
Additionally, Jane advises private companies and projects focused on regenerative finance, sustainability, machine learning, digital identity and on-chain AML and sanctions compliance. She also serves as an expert witness in civil cases at the intersection of money laundering, financial crimes, corruption and human trafficking, and she is frequently invited to speak and train private and public sector actors on these issues.
Prior to joining the Foundation, Jane was a Trial Attorney and Human Trafficking Finance Specialist with the U.S. Department of Justice’s Money Laundering and Asset Recovery Section (DOJ/MLARS), where she investigated and prosecuted multi-jurisdictional and international money laundering and financial crimes, including those involving virtual currency and exchanges, Bank Secrecy Act (BSA) violations, human rights, human trafficking, corporate supply chains, and child exploitation. She regularly provided subject matter expertise, guidance and training to DOJ litigating components, U.S. Attorney's Offices, and international, federal, state, and local law enforcement on issues relating to money laundering, financial crimes, forfeiture and restitution. She co-authored “Prosecuting Sex Trafficking Cases in the Wake of the Backpage Takedown and the World of Cryptocurrency,” 69 Dep't of Just. J. Fed. L. & Prac. 101 (2021), published in the Department of Justice Journal of Federal Law and Practice. Prior to DOJ, Jane investigated and prosecuted enterprise corruption, money laundering, financial crimes and public corruption cases in the New York County District Attorney’s Office and the New Jersey Attorney General’s Office. Jane earned her Juris Doctor from the University of Michigan Law School, and Bachelor in Arts from Barnard College, summa cum laude.
Matt McGuire
Partner
Matt McGuire is a Partner at Arktouros PLLC. His experience combines litigation at every level of federal and state judicial systems, including the U.S. Supreme Court, with practical, international commercial and emerging technology in-house expertise. Before joining the firm, he served in government, private practice, and academia along with deep in-house global experience at both public (Shopify) and private (DeFi Labs GmbH) international tech companies. From initial domestic or foreign government inquiry to oral argument in the U.S. Supreme Court, Matt has been involved in innumerable types of criminal and civil government investigation and litigation matters, including major cross-border disputes and crisis/incident response.
Matt’s public service and private practice experience was primarily as litigator and government investigation lawyer, handling significant appellate matters, trial court motions, litigation strategy, and investigations/subpoenas. As Virginia’s first Principal Deputy Solicitor General, he argued and won (5-4) a complex double jeopardy case in the U.S. Supreme Court (Currier v. Virginia). Matt has been counsel of record in more than 40 other Supreme Court matters, argued more than 20 appellate cases across wide-ranging subjects, and led the briefing strategy in more than 100 cases. Matt uses his appellate experience to efficiently embed with trial and arbitration teams to develop legal strategy and prepare major motions.
Matt was enticed away from private practice by the opportunity to be Shopify’s first global regulatory lawyer, and by the time he left Shopify, he had served as head of Shopify’s data protection legal team, led policy engagement for major European tech regulations (Digital Markets Act and Digital Services Act), and served as Senior Advisor/Deputy to the General Counsel to oversee the most difficult and complex legal issues facing the company. As General Counsel/Chief Compliance Officer at DeFi Labs GmbH, Matt guided the team through the numerous issues affecting a venture-backed startup while working closely with the founders and product team on the global legal obligations for crypto/blockchain.
Between his public service, private practice, and in-house experiences, Matt’s advised on matters involving innumerable government actors in the United States (e.g., US Congress, CFPB, DHS, DOJ, FBI, FERC, FTC, SEC, and State Attorneys General and state agencies), European Union and individual Member States, United Kingdom, Canada, Japan, Singapore, Argentina, Cayman Islands, and South Africa, among others.
Matt frequently is asked to speak on oral advocacy, and people have noted the “exceptionally high intellectual plane” of the oral argument in his cases. He’s also published several law review articles, including a recent one on personal jurisdiction, crypto, and DAOs. He’s previously taught a law school course on State Constitutions and State Attorneys General at the University of Richmond.
Michael Parker
Partner
Michael (Mike) Parker is a Partner at Arktouros PLLC. Prior to this role, he served as the head of the anti-money laundering and sanctions practice at a prominent Washington, D.C. law firm specializing in U.S. economic sanctions administration and compliance. In private practice, Mr. Parker was the principal attorney responsible for the very first successful lifting of U.S. economic sanctions of a Russian national following the invasion of Ukraine from the Specially Designated Nationals List (SDN List) administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). His current and previous clients include prominent industrialists, top financial institutions, and private equity funds, in addition to international expert witness engagements. Additionally, Mr. Parker is an Adjunct Professor of National Security Law in the Georgetown University Security Studies Program.
Mr. Parker is a former federal prosecutor with the U.S. Department of Justice’s Money Laundering and Asset Recovery Section (MLARS), where he served as a subject matter expert on economic sanctions for MLARS and U.S. Attorneys’ Offices across the country. During his six-plus years at MLARS, Mr. Parker was responsible for money laundering and forfeiture investigations of transnational criminal organizations and foreign threat actors, including serving as the lead MLARS prosecutor for the “Panama Papers” case. Among his matters, Mr. Parker prosecuted cases involving major international financial institutions, foreign ransomware actors, hostile adversarial nations, criminals who launder funds through cryptocurrency, and complex trade-based money laundering networks. In 2017, the Federal Bureau of Investigation (FBI) awarded Mr. Parker with the FBI Director’s Award for Outstanding Counterintelligence Investigation for his work on a North Korea-related sanctions evasion and money laundering case that was perpetrated through the U.S. banking system.
Prior to his time at DOJ, Mr. Parker spent nearly eight years at OFAC where he served as a Sanctions Investigator, and later a Section Chief in OFAC’s Enforcement Division. During his tenure at OFAC, Mr. Parker was responsible for sanctions investigations of transnational criminal organizations, cartel-related targets under the Foreign Narcotics Kingpin Designation Act, and high-profile Middle Eastern sanctions targets under various legal authorities. He also held supervisory authority over one of three OFAC Enforcement divisions and was the supervisory enforcement officer for violations of U.S. sanctions programs.
Rebecca Rettig
Of Counsel
Rebecca Rettig is Of Counsel at Arktouros PLLC. She is currently general counsel of a large international software development company that builds blockchain scaling infrastructure, including aggregated network scaling. Prior to her current role, Rebecca was general counsel at a software development company building DeFi and other blockchain-based applications. The majority of her preceding career was outside counsel -- at Cravath, Swaine and Moore LLP she represented clients in litigation and enforcement matters, including on both the financial services side and in early peer-to-peer technology litigation. After Cravath, Rebecca dedicated her legal career to representing software development companies in the blockchain space, advising clients on legal and regulatory matters relating to novel technologies and litigating some of the earliest crypto lawsuits and regulatory enforcement matters and investigations.
Insights & Publications
Explore insights from our forefront thinkers on cryptocurrency, DeFi, and compliance, with publications ranging from regulatory frameworks to innovative financial technologies.
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