Siana Danch

Siana Danch is a litigation attorney in Holland & Knight's Philadelphia office. Ms. Danch focuses her practice on federal tax controversy, regulatory enforcement, anti-money laundering (AML) compliance, internal investigations and white collar defense.

Ms. Danch has extensive experience in defending clients before the IRS in matters involving criminal and civil tax fraud, assessment and collection actions. She has handled a variety of federal trial and appellate court pleadings, including refund suits, deficiency petitions and an appellate brief on Report of Foreign Bank and Financial Accounts (FBAR) penalty issues. Ms. Danch has also assisted clients in responding to federal and state civil and criminal investigations involving tax and money laundering compliance, as well as John Doe summons.

Ms. Danch also advises U.S. and non-U.S. financial institutions and other businesses, including money transmitters, gaming institutions and real estate industry participants, on AML and Office of Foreign Assets Control (OFAC) compliance and emerging trends, including cryptocurrency regulation, and assists clients in examinations and investigations arising under the Bank Secrecy Act (BSA) and federal money laundering statutes. Ms. Danch's work includes drafting and revising compliance policies and procedures, developing risk assessments, conducting AML due diligence during merger and acquisition (M&A) transactions, and conducting enhanced due diligence on certain customers and transactions and determining whether to close customer accounts. She also advises on compliance relating to bank and financial technology (FinTech) partnerships as well as helps financial institutions respond to investigations and subpoenas and contest the application of "special measures" for a foreign financial institution designated as a "primary money laundering concern."

In addition to her legal practice, Ms. Danch maintains an active pro bono practice and volunteers as a tax return preparer for low-income residents of Philadelphia.

Prior to joining Holland & Knight, Ms. Danch was an attorney at national law firms in Philadelphia. Previously, she served as a judicial law clerk to the Honorable Richard T. Morrison of the U.S. Tax Court, as well as completed internships in the IRS Office of Chief Counsel.

While in law school, Ms. Danch traveled to rural Alaskan villages as a volunteer tax return preparer.

Representative Experience

• Assisted in filing an amicus brief on behalf of a major industry group contesting AML regulations promulgated by Financial Crimes Enforcement Network (FinCEN)
• Successfully defended a major international corporation in a wide-ranging civil tax fraud investigation and audit relating to a 10-figure intercompany transaction and nine-figure monetary liability; resulted in no fraud penalty
• Secured a favorable resolution for a financial institution in federal regulatory examination of alleged BSA violations; resulted in no consent order
• Successfully assisted numerous individuals and businesses accused of multimillion-dollar federal tax fraud schemes, including alleged income tax evasion, tax shelter and payroll schemes
• Representation of employees of a major financial institution in a U.S. Department of Justice (DOJ) Money Laundering and Asset Recovery Section (MLARS) investigation alleging BSA and money laundering violations
• Representation of a financial institution in a DOJ investigation regarding alleged BSA and sanctions violations involving cryptocurrency exchangers and prepaid cards
• Successfully convinced the IRS to abate an entire potential seven-figure penalty for a gaming institution client that allegedly failed to file IRS reporting forms for winnings by internet sports betting clients
• Advising a major financial institution on civil litigation and discovery issues regarding tort claims relating to the institution's operation of its AML and compliance systems