Overview

Kerry Zinn’s practice focuses on helping financial institutions, publicly traded companies and others comply with their regulatory obligations.  Kerry has been a regulatory lawyer for over two decades and has experience with virtually all the regulatory issues that impact small and large broker-dealers, investment advisers, funds, issuers and others. She is even knowledgeable and experienced with specialized regulatory topics such as cross-border issues, FATCA, fraud, cybersecurity, money laundering, sanctions and anti-bribery and corruption.  Indeed, a core area of Kerry’s practice is advising on compliance and handling issues relating to the Bank Secrecy Act, PATRIOT Act, OFAC requirements and the Foreign Corrupt Practices Act for banks, broker-dealers, money services businesses and others.  Her Financial Crime Compliance practice includes working on cutting edge issues such as designing and advising on anti-money laundering compliance programs for financial institutions who bank state legalized marijuana and for cryptocurrency exchanges.  

Kerry was in-house counsel for UBS AG for 15 years.   Most recently she was UBS’s head attorney for Financial Crime Compliance in the Americas Region.   Kerry represented UBS’s broker dealers, investment banks, private banks, trust companies, asset managers and hedge funds in the U.S., Canada, Mexico and Brazil on all significant anti-money laundering, sanctions and anti-bribery and corruption issues.  She represented UBS’s lines of business during financial crime compliance regulatory examinations, investigations and enforcement actions by FINRA, the SEC, FinCen, FDIC, OCC and the Fed.  Kerry was the point person for annual independent audits and oversaw the production of documents and information to the auditors.  She headed large scale remediation and implementation projects including the implementation of the Customer Due Diligence Rule across all UBS business lines.  Kerry managed the teams responsible for the over 90 financial crime-related policies and procedures and training programs.   

Prior to her role in Financial Crime Compliance, Kerry was a senior regulatory lawyer for UBS’s retail broker-dealer.  Kerry handled a myriad of regulatory matters ranging from sales practice violations, product failures, trading and trade reporting violations, anti-money laundering and more.  Kerry was involved with some of the most complex and highest profile regulatory cases in the past decade.  For example, she was one of the lead lawyers who represented UBS’s retail broker-dealer during the investigations and subsequent enforcement actions by state regulators, FINRA and the SEC due to the failure of the auction rate securities market.  Kerry also served as the U.S. securities law adviser in Zurich Switzerland for UBS’s settlement execution project stemming from a deferred prosecution agreement with the Department of Justice and SEC consent order resulting from UBS’s cross-border activities with U.S. persons.  

Before she joined UBS, Kerry was senior trial counsel with the SEC.  She litigated dozens of cases in federal court.  Kerry also handled administrative proceedings and argued an appeal before the Commissioners.  She managed staff attorneys who second chaired the litigations and paralegals.  Immediately after law school, Kerry clerked for two federal judges in the U.S. District Court for the Southern District of Florida.

As a result of her time in-house, Kerry understands the needs of in-house counsel and their business clients.  Her goal is to always provide timely, accurate, clear and practical advice.  The time that Kerry spent in-house as the lead attorney for a large financial institution’s financial crime compliance program sets her apart from other lawyers in that practice area.   In addition to advising on black letter of the law and what the regulations state, Kerry advises her clients on how to effectively implement AML Program requirements and best practices.  Lastly, as a former regulator Kerry understands how regulators think and what the best approach is during regulatory investigations.   She also vigorously defends and advocates on behalf of her clients when necessary to obtain the most favorable result.

Experience

Experience

  • Lead counsel on all anti-money laundering substantive issues in connection with contemporaneous enforcement actions by FINRA, SEC and FinCen against a major retail broker-dealer and was instrumental in negotiating no undertakings and demonstrating mitigating factors to reduce fine to $15 million
  • Designed anti-money laundering compliance program including customer due diligence and monitoring for credit union banking medical marijuana
  • Performed regulatory audit of payment processor’s anti-money laundering policies and procedures for handling proceeds from medical marijuana and CBD
  • Advised regional broker-dealer about customer due diligence and monitoring requirements and best practices applicable to cryptocurrency exchange customers and the risks with relating thereto
  • Advised regional broker-dealer on what customer due diligence was legally sufficient relating to multilayered complex offshore legal entity account holders with multiple accounts worth hundreds of millions of dollars
  • Represented investment adviser during SEC investigation of 12b-1 fee disclosures and persuaded the Division of Enforcement to close the matter with no charges.
  • Represented a broker-dealer in connection with FINRA’s 529 Self-Reporting Initiative and advised on remediation plan
  • Represented an investment adviser during Florida Office of Financial Regulation testimony regarding deceptive and unfair business practices
  • Represented major broker-dealer in garnishment action in federal court seeking to attach blocked assets of a sanctioned customer to satisfy a judgment obtained pursuant to Terrorism Risk Insurance Act
  • Advised major broker-dealer on the provision of financial services in various countries and wrote policies relating thereto
  • Assisted a broker-dealer in the United Kingdom on IRS qualified intermediary application and its FATCA compliance program
  • As in-house counsel, vice-chaired customer due diligence implementation project spanning multiple business lines including a retail broker dealer, investment bank, private bank and asset manager
  • Represented senior financial crime compliance management during on-the-record testimony relating to program deficiencies
  • Provided advice and oversaw the document production during a multi-year examination of a major broker-dealer’s anti-money laundering program by FINRA’s anti-money laundering compliance examination team 
  • One of the lead in-house counsel representing a major broker-dealer in connection with contemporaneous investigations by a self-regulatory organization, multiple states and the SEC about the failure of the auction rate securities market
  • Lead in-house counsel in enforcement actions by FINRA for Reg SHO and LOPR reporting violations and handled a multitude of capital market inquiries relating to TRACE, mark ups, best execution and other capital market issues
  • Handled FINRA membership continuation applications due to statutory disqualifications
  • Ran a global project for global bank from Zurich, Switzerland to identify broker-dealers around the world with US person customers
  • Lead U.S. securities adviser to global bank about requirements associated with providing cross-border financial services to person in the U.S. during execution of a settlement project to comply with Department of Justice deferred prosecution agreement and SEC consent order
  • Primary drafter of U.S. Person training while in-house counsel on international assignment which was completed by 40,000 employees for global bank
  • Trained legal departments in Australia, Singapore and Hong Kong about U.S. securities laws and requirements and limitations associated with providing cross-border financial services to U.S. persons when in-house counsel on international assignment
  • Brought the SEC’s first enforcement against a hedge fund worth over a billion dollars for market manipulation and argued successfully in federal court for an ex-parte asset freeze and appointment of court appointed receiver
  • Litigated multiple cases relating to pump and dumps and fraudulent offerings while SEC trial counsel and worked extensively with court-appointed receivers
  • Argued an appeal before the SEC Commissioners relating to a complex issue associated with municipal securities and disgorgement and won.  

News & Insights

Speaking Engagements & Events

Publications

Associations & Organizations

Professional Affiliations

  • University of Samford Cumberland School of Law; Adjunct Anti-Money Laundering Professor
  • Florida International Banking Association (FIBA); member
  • Securities Industry Financial Association (SIFMA); member
  • Florida Securities Dealers Association (FSDA); advisory board member
  • Southern Women in Financial Services Association (SWIFS); member

Get to Know Kerry

Get to Know Kerry

When not working, Kerry volunteers for an animal rescue and enjoys adventure travel.   She is also an avid boater and enjoys snorkeling and offshore fishing. 

Education

  • University of Miami School of Law, J.D., cum laude, 1997
  • University of Michigan, B.A., 1993

Admissions

  • Florida
  • U.S. District Court, Southern District of Florida
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