Task Force on Gatekeeper Regulation and the Profession

Welcome to the home page of the ABA Task Force on the Gatekeeper Regulation and the Profession. Our Task Force was created in February 2002 by ABA President Robert Hirshon to examine U.S. government and multilateral efforts to combat international money laundering and the implications of these efforts for lawyers and the profession. The legal profession, as well as certain financial sector professions, have been characterized as the "gatekeepers" to the international financial and business markets.

The mission of the Task Force is to respond to initiatives by the U.S. Department of Justice and other organizations that will impact on the attorney-client relationship in the context of anti-money laundering enforcement. We are reviewing and evaluating ABA policies and rules regarding the ability of attorneys to disclose client activity and information, and developing a position on the Gatekeeper issue. We are developing educational programs for legal professionals and law students, and organizing resource materials to allow lawyers to comply with their anti-money laundering responsibilities. The goal is to preserve the integrity of the attorney-client relationship.

On this page, you will find information on who we are, the Gatekeeperer Initiative.

- William H. Clark, Jr., Chair

Latest Developments and Key Materials

Laurel Terry and José Robles Law Review Article: "The Relevance of FATF's Recommendations and Fourth Round of Mutual Evaluations to the Legal Profession," (Fordham Int’l Law Journal, 2018)

FATF Mutual Evaluation Report on United States’ Anti-money Laundering and Counter-terrorist Financing Measures (December 2016)

U.S. Treasury Department's Specially Designated Nationals List (August 5, 2015)

ABA President William Hubbard Op-Ed Praising Canadian Supreme Court Decision“: Confidentiality Versus Money-Laundering Laws” (National Law Journal, March 10, 2015)

2014/2015 New York Law School Symposium Articles

FATF AND THE GOO 2014/2015 New York Law School Symposium Articles

D PRACTICES GUIDANCE / Basic Client Intake

ABA/IBA/CCBE Lawyer's Guide to Detecting and Preventing Money Laundering (October 2014)

Conference of Chief Justices Resolution Supporting the Voluntary Good Practices Guidance and the Risk-Based Approach (July 2013)

FATF Documents and Related ABA Comments

FATF Typologies Report (June 2013)

The FATF Standards (February 2012)

Risk Based Approach Guidance for Legal Professionals (October 23, 2008)

FATF Consultation Paper: The Review of the Standards--Preparation for the 4th Round of Mutual Evaluations

ABA Comments on FATF's Draft Report on Money Laundering Vulnerabilities of Legal Professionals (May 6, 2013)

ABA Advises Treasury Department and FATF of the Bar's Efforts to Fight Money Laundering (November 26, 2012)

ABA Letter to FATF Providing Reactions to Revised International Anti-Money Laundering Standards (March 27, 2012)

ABA Submits Further Follow-Up Comments to FATF Consultative Meeting in Milan (December 13, 2011)

ABA Submits Additional Comments on FATF Consultation Paper (September 16, 2011)

ABA Seeks Dialogue with FATF Regarding Proposed New International Anti-Money Laundering Standards (June 17, 2011)

ABA Submits Initial Follow-Up Comments to FATF Consultative Meeting in Milan (January 7, 2011)

Other Organizations’ Comments to FATF Consultation Paper

CCBE Letter (June 20, 2011)

JFBA Letter (June 20, 2011)

The Law Society of England and Comments on the FATF Consultation Paper (January 2011) (The Law Society site)

Senator Levin's Subcommittee Comments on the FATF Consultation Paper (January 6, 2011)

Other ABA Letters and Comments

ABA Urges State and Local Bar Members to Follow ABA Formal Ethics Opinion 463 and Voluntary Lawyer Guidance (July 31, 2013)

ABA Urges State and Local Bar Members to Follow Voluntary Lawyer Guidance (April 8, 2011)

ABA Policies and Positions

ABA Resolution 104 Supporting Reasonable and Balanced Anti-Money Laundering Initiatives Consistent with the Confidential Lawyer-Client Relationship (February 2003)

ABA Resolution 300 Opposing Federal Beneficial Ownership Reporting Mandates and Regulation of Lawyers in Formation of Business Entities (August 2008)

ABA Resolution 116 Adopting the Voluntary Good Practices Guidance for Lawyers to Detect and Combat Money Laundering and Terrorist Financing (August, 2010)

Text of Voluntary Good Practices Guidance for Lawyers to Detect and Combat Money Laundering and Terrorist Financing

Reference Materials

Financial Action Task Force

ABA Governmental Affairs Office: "Independence of the Legal Profession: Gatekeeper Regulations on Lawyers"

2010 ABA J. Prof. Law. Symposium on Gatekeeper Issues: 

The articles are available here (click on 2010).

The articles are also listed on the IBA Anti-Money Laundering ForumWebpage.

ABA Journal "Into the Breach" article from Oct 2011


Frequently Asked Questions about the Gatekeeper Initiative and the Voluntary Good Practices Guidance


Chair: William H. Clark, Jr., Philadelphia, PA


Hdeel Abdelhady, Silver Spring, MD

Alma M. Angotti, Washington, DC

John M. Barkett, Miami, FL

Michael St Patrick Baxter, Washington, DC

Elwood F. Cahill, Jr., New Orleans, LA

Garth Jacobson, Seattle, WA

George W. Madison, New York, NY

Jenny Mittelman, Atlanta, GA

Carolyn A. Reers, New Haven, CT

William E. Stern, New York, NY

Laurel S. Terry, Carlisle, PA

Bruce Zagaris, Washington, DC

Board Liaison: Kevin L. Shepherd, Baltimore, MD

Staff: Larson Frisby, Washington, DC