Government Service

Prior to Paul, Weiss, Roberto served as Associate White House Counsel and Special Assistant to President Obama, where he counseled on Dodd-Frank, homeland security, congressional investigations, and a variety of sensitive internal matters. He then became a founding employee of the Consumer Financial Protection Bureau (CFPB) and served as Principal Deputy General Counsel. In that role, he advised the Director on all rulemakings, enforcement actions, and significant supervisory matters. Roberto then became Deputy General Counsel of the Treasury Department, where he oversaw major litigations, congressional investigations, and sensitive internal matters and supervised over 100 lawyers in the areas of sanctions, anti-money laundering, Dodd-Frank, cybersecurity, and ethics and employment matters.

EXPERIENCE

Sanctions, AML, National Security:

• a top-five global bank in an investigation by the Manhattan U.S. Attorney’s Office related to U.S. dollar-clearing activity and related anti-money laundering (AML) controls and in a prior investigation by the Federal Reserve and the New York Department of Financial Services regarding alleged sanctions violations;
• Shinhan Bank America in the successful settlement of AML inquiries involving the New York State Department of Financial Services, the FDIC, and FinCEN;
• the National Bank of Pakistan and its New York branch in a successful resolution of sanctions/AML compliance investigations by the New York Department of Financial Services and Federal Reserve;
• a major U.S. fintech in criminal and regulatory investigations regarding anti-money laundering compliance;
• a major non-U.S. bank in a review of its private bank’s potential Russian sanctions exposure;
• multiple other global financial institutions and other companies in a variety of internal investigations and criminal and regulatory investigations regarding allegations of sanctions and anti-money laundering violations and related employee misconduct;
• a leading technology company and a leading financial services company in multi-disciplinary reviews of their compliance programs, including in the areas of sanctions and AML compliance;
• multiple U.S. and non-U.S. clients in interactions with OFAC regarding licensing applications, requests for interpretive advice, de-listing requests, and the filing of voluntary disclosures and responses to document requests;
• a major non-U.S. technology company in engaging with multiple U.S. government agencies regarding privacy, data security, and national security concerns regarding an app;
• a major non-U.S. technology company in defending a Commerce Department investigation of a technology offering under the ICTS regulations;
• an indenture trustee and collateral agent in litigation in the District Court for the Southern District of New York concerning the enforceability of senior secured notes issued by Petroleos de Venezuela, S.A. and related sanctions issues;
• multiple technology companies on sanctions compliance program enhancements;
• multiple asset managers in connection with due diligence and advice on compliance and regulatory issues in potential transactions spanning the areas of sanctions/AML, consumer financial protection, cryptocurrency, and matters; and
• multiple financial institutions in connection with regulatory advice concerning the marijuana/cannabis industry in the United States and Canada.

CFPB and Consumer Protection:

• several U.S. banks in a comment letter to the CFPB regarding its credit card late fee rulemaking proposal;
• a major U.S. bank in connection with a favorable, no-penalty settlement with the CFPB and follow-on settlements with state Attorneys General;
• a U.S. multinational technology company in a CFPB inquiry into the business practices of so-called “Big Tech” companies operating payments products;
• a U.S. nonbank company in proceedings by the CFPB to designate the company for supervision based on its “risks to consumers” authority; and
• an international Fortune 50 corporation in connection with subpoenas from a group of State Attorneys General and a lawsuit from the DC AG claiming unfair practices related to a prior multimillion-dollar settlement the company entered into with a federal regulator.

Congressional Investigations:

• a major U.S. bank in connection with an industry-wide House committee investigation regarding financial dealings with a higher-risk jurisdiction;
• a major U.S. bank in connection with a subpoena by the S. Select Committee on January 6^th and House Oversight and Reform Committee for a customer’s financial records, and in successfully defending a federal lawsuit brought by the customer for alleged violations of the Right to Financial Privacy Act;
• a non-U.S. e-commerce platform in responding to a subpoena by the U.S. Select Committee on January 6^th and House Oversight and Reform Committee;
• a national trade association in connection with a House investigation regarding climate change as well as preparing the CEO for successful testimony in a committee hearing;
• a major U.S. bank in an investigation by the House Select Committee on the Coronavirus regarding the operation of the Paycheck Protection Program (PPP) and concerns regarding access by minority and low-income borrowers;
• an American multinational technology company in connection with its response to an investigation by the House Oversight and Reform Committee related to a natural disaster and worker safety at the retailer’s facilities, as well as an investigation by a Senate committee regarding worker safety;
• a former cabinet official in high-profile congressional inquiries;
• a U.S. bank with regard to a congressional inquiry regarding its actions and policies towards firearms; and
• an American apparel corporation in responding to requests from the House Select Committee on China in relation to the sourcing of materials from the Uyghur Region.

Other Investigations and Litigations:

• A multinational technology conglomerate in one of the largest publicly announced racial equity audits, analyzing the company’s overall policies, practices, programs and initiatives to determine their racial impacts on the company’s wage-earning employees;
• Blackrock in an internal investigation into former employees’ allegations of sexual harassment and discrimination;
• Citigroup Inc. and affiliates in an ongoing multidistrict putative class action alleging that Citi and other banks conspired to reduce potential competition in interest rate swap trading, and a related CFTC investigation;
• Binance in:
  • the dismissal of a lawsuit brought by former consultant alleging conversion, unjust enrichment and negligence related to cryptocurrency allegedly confiscated from his account after the consulting arrangement ended; and
  • federal and state court lawsuits regarding the operation of its exchange.
• A major U.S. bank in an internal investigation and accountability review regarding allegations of potential employee misconduct and compliance program failures;
• A major private equity firm in connection with allegations of internal misconduct, conflicts of interest and theft of proprietary information;
• a U.S. equipment manufacturer in a DOJ False Claims Act criminal and civil investigation;
• a private equity firm in connection with a False Claims Act civil investigation by DOJ in the health care industry, which resulted in a declination; and
• the American Bar Association in an amicus brief filed in the Bruen case in the U.S. Supreme Court concerning the constitutionality of New York’s firearm licensing law.

Roberto has appeared on CNBC and NPR’s Morning Edition and speaks and writes frequently on compliance and regulatory issues. His articles and other publications have appeared in American Banker, Law360, the National Law Journal, the Harvard Law School Forum on Corporate Governance and Financial Regulation, and the Columbia Law School’s Blog on Corporations and the Capital Markets. He also co-authored an expert analysis chapter in Global Legal Insight’s Blockchain & Cryptocurrency Laws and Regulations 2023 and contributed the USA chapter and an expert analysis chapter for the International Comparative Legal Guide – Sanctions 2024. Roberto was selected to receive the “Law360 Distinguished Writing Award.”

Roberto served as a member of Paul, Weiss’s diversity and inclusion task force, and chairs the Washington D.C. office’s diversity committee. Prior to his government service, he served as a fellow at a non-profit organization litigating employment discrimination and related cases.