Dustin Palmer is a Financial Crimes Compliance practice leader and co-leader of the Blockchain, Cryptocurrency & Digital Assets practice at Berkeley Research Group, LLC.
He is an expert in financial institutions and regulatory compliance, with a focus on anti-money laundering (AML), sanctions, fraud, anti-bribery and -corruption (ABC), and related areas. Mr. Palmer assists clients in regulatory, litigation, and enforcement matters, with a particular emphasis on identifying money laundering and suspicious activity; technology, analytics, and machine learning; transaction monitoring; customer due diligence; risk assessments; and reducing high risk in areas such as digital assets and correspondent banking.
Mr. Palmer is also an expert in financial crimes compliance as it relates to cryptocurrencies, stablecoins, nonfungible tokens (NFTs), decentralized finance (DeFi), and related areas, including blockchain analytics tools, proof-of-work (PoW), staking-as-a-service, and proof-of-stake (PoS). He has assisted with bank charters and worked with financial institutions, regulators, and individuals around the world to set up programs and systems to help track and trace money laundering and sanctions compliance.
Mr. Palmer has testified in multiple money laundering-related cases. Most recently, he testified in the Southern District of New York regarding typical money laundering patterns for individuals and small businesses. He also has testified regarding the use of privacy coins, noncustodial wallets, and layering techniques. In a separate case, and given his extensive government and industry experience, he testified regarding the financial industry effects of the US government pursuing special measures under the USA PATRIOT Act Section 311.
Before joining BRG, Mr. Palmer was at a global consulting firm where he focused on the financial services industry for ten years and led the financial crimes compliance practice for the Americas. Fluent in English and Spanish, he worked throughout the United States, UK, Europe, Canada, Central and South America, and Asia. He has led large remediation efforts for financial institutions, mapped and reduced risks, implemented advanced technologies, and increased the efficiency and effectiveness of institutions’ risk compliance programs. He is also often an expert in financial crimes-related litigation and a frequent speaker on panels and seminars.
Previously, Mr. Palmer was senior advisor to the general counsel and senior counsel for enforcement and intelligence at the US Department of the Treasury. He worked closely with FinCEN, the Office of Foreign Assets Control (OFAC), and the departments of Commerce, State, and Justice to evaluate anti-fraud, sanctions, and money laundering programs throughout the world; and to implement policies and regulations that would reduce organized crime and help secure the US financial system. He also was integrally involved in the Troubled Asset Relief Program (TARP), along with interpreting and establishing data protection and privacy standards, including being part of an international negotiating team dealing with the sharing of personal data between Europe and the United States.
Prior to his tenure at Treasury, Mr. Palmer worked as an attorney for the US Department of Homeland Security in the Office of Legal Counsel, including with US Immigration and Customs Enforcement and US Customs and Border Protection to identify and prosecute money laundering and smuggling cases. Earlier in his career, he was an attorney, a law clerk to Judge Karen J. Williams of the US Court of Appeals for the Fourth Circuit, and an assistant to Judge Richard Posner, William Landes, and James Heckman.
Mr. Palmer holds a JD from the University of Chicago Law School and a BA in economics from Brigham Young University.
Areas of Expertise
University of Chicago Law School
Brigham Young University