O’Melveny Worldwide

AnnaLou Tirol counsels clients on anti-money laundering (AML) and fintech regulatory, compliance, and enforcement issues, drawing on two decades of government experience, most recently as Deputy Director of the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN).

Few lawyers share AnnaLou’s deep familiarity with AML laws and regulations. As FinCEN’s Deputy Director, the bureau’s second highest official, AnnaLou oversaw FinCEN’s operations, programs, and policy, including legislative and regulatory matters, public-private partnerships with financial institutions and fintechs, and enforcement and compliance matters related to the Bank Secrecy Act (BSA). Following Congress’ January 2020 enactment of the Anti-Money Laundering Act of 2020, AnnaLou led FinCEN’s implementation of the most significant legislation to modernize the BSA since the USA PATRIOT Act, including the Corporate Transparency Act’s beneficial ownership requirements.

Prior to joining FinCEN, AnnaLou served as the Acting Chief of the Public Integrity Section of the U.S. Department of Justice’s (DOJ) Criminal Division from 2016 to 2019. In that role, she oversaw approximately 35 prosecutors litigating sensitive and complex public corruption and election crimes cases nationwide. In her 15 years with DOJ, AnnaLou served in multiple capacities, including as an Assistant U.S. Attorney in the Southern District of California, leading complex white collar investigations and prosecutions involving financial fraud, public corruption, money laundering, and other crimes, and trying 15 jury trials to verdict. She also served as an overseas Legal Advisor for DOJ, running rule of law programs targeting money laundering, public corruption, terrorist financing, fraud, and financial crimes in Panama City, Panama and Belgrade, Serbia.

AnnaLou is also committed to mentoring and developing young and diverse attorneys. She is an Adjunct Professor of Law at Georgetown University Law Center and was a founding member of FinCEN’s Women’s Leadership Series

Read More


Bar Admissions

  • California
  • District of Columbia

Court Admissions

  • US Tax Court, Southern District of California


  • University of San Diego School of Law, J.D.
  • University of San Diego School of Law, LL.M.
  • University of Notre Dame, B.A.

Honors & Awards

  • U.S. Department of the Treasury Distinguished Service Award
  • U.S. Department of State’s Meritorious Honor Award
  • Assistant Attorney General’s Award for Distinguished Service
  • FinCEN Director’s Award for Excellence in Diversity and Inclusion

Professional Activities


  • “International Reporting, Compliance & Enforcement,” 16th Annual STEP International Tax and Estate Planning Forum (June 13, 2024)
  • “Corporate Transparency Act (CTA) Update,” New York Bar Association (May 13, 2024)
  • “The CTA and LLC Transparency Act – Where Are We Now,” Business Law Section and Corporate Counsel Section NYSBA Annual Meeting (January 17, 2024)
  • “The Corporate Transparency Act—Dealing with the New World of Beneficial Ownership and Control Disclosure,” 82nd Institute on Federal Taxation (November 13, 2023)
  • "CTA Implementation: What Do International Banks Need to Know?" Institute of International Bankers Annual Anti-Money Laundering Conference (September 26, 2023)
  • "Leveraging Blockchain, Investigations, and Enforcement Actions," ACAMS US Capital Chapter: Cryptocurrency Forum: Intersection of ML/CFT & Emerging Risks (April 19, 2023)
  • "Getting your house in order before January 2024," STEP (March 29, 2023)
  • "Advancing Rule of Law Abroad," Asian Pacific American Bar Association DC (March 23, 2023)
  • "Unpacking AML Reform: The US AMLA 2020, UK Economic Crime Bill and EU AML Package 2021," ACAMS (March 9, 2023)
  • "The Corporate Transparency Act - Part 2," New York State Bar Association (February 28, 2023)
  • "Compliance with the Corporate Transparency Act," USC Gould School of Law 2023 Tax Institute (January 25, 2023)
  • "The CTA Is Coming! What All Business Attorneys Need To Know About The Corporate Transparency Act," New York State Bar Association (December 8, 2022)
  • "WTF Is An NFT?: Navigating the Fast-Evolving Legal Landscape Surrounding Digital Assets," 2022 National Asian Pacific American Bar Association (NAPABA) Convention (November 4, 2022)


  • Honorable Ruben B. Brooks, U.S. Magistrate Judge, Southern District of California

Adjunct Professor

  • Georgetown University Law Center

Founding Member

  • Women’s Leadership Series, FinCEN

Corporate & Government Experience

Government Experience

  • Deputy Director, Financial Crimes Enforcement Network, U.S. Department of the Treasury
  • Acting Chief, Public Integrity Section, Criminal Division, U.S. Department of Justice
  • Assistant U.S. Attorney, U.S. Attorney’s Office, Southern District of California
  • Resident Legal Advisor, Office of Overseas Prosecutorial Development, Assistance and Training, Criminal Division, U.S. Department of Justice