Jennifer Jacoby Altscher

Senior Associate


Jennifer Jacoby advises clients on financial services matters, with a particular focus on anti-money laundering (AML) and fair lending compliance and enforcement. She also provides insight into legal and regulatory issues related to emerging payments, including virtual currencies such as Bitcoin.

Ms. Jacoby has advised a range of financial institutions, including banks, broker-dealers, money services businesses, casinos and insurance companies, on AML compliance, investigations and enforcement actions. Most recently, Ms. Jacoby assisted in the representation of a broker-dealer in an enforcement action brought by the Financial Crimes Enforcement Network. She also drafts a range of AML policies and procedures for financial institution clients, and has provided AML counseling to emerging payments clients. 

Ms. Jacoby also assists clients with the lifecycle of responding to government inquiries and examination findings with respect to a range of consumer financial protection matters.

While pursuing her legal education, Ms. Jacoby served as a judicial intern for the Hon. Richard J. Leon of the US District Court for the District of Columbia, where she helped the Judge and law clerks with legal research, drafted memoranda and attended hearings.

Community Involvement

Ms. Jacoby previously served as a volunteer for the American Civil Liberties Union’s Bailey Litigation Project, in Philadelphia, Pennsylvania, helping to analyze reports to determine whether police officers inappropriately stopped citizens in preparation for trial.

Honors & Awards

  • Named a 2014 and 2015 Empire State Counsel by the New York State Bar Association for her dedication to pro bono service

Publications & News


December 1, 2017

The Equal Rights Center Resolves Race and Source of Income Discrimination Complaint Through Robust, Court Enforced Agreement with DC Housing Provider

The ERC, a civil rights organization that seeks to promote equal opportunity in housing, has entered into a consent agreement with The Lenkin Company Management/Residential, Inc. and related entities.

April 13, 2017

Property Management Company's Refusal to Rent to District Voucher Holders is Unlawful Discrimination

The Equal Rights Center, a civil rights organization that seeks to promote equal opportunity in housing, filed a lawsuit against The Lenkin Company Management, Inc., a residential property management firm, and related entities for violating the DC Human Rights Act and the federal Fair Housing Act for discriminatory rental practices.

June 16, 2016

WilmerHale Wins Bank of America Award for Diversity and Inclusion

WilmerHale was recognized for creating an internal culture that encourages the recruitment, retention, mentoring and promotion of diverse attorneys.

May 31, 2016

FinCEN Finalizes Beneficial Ownership and Customer Due Diligence Requirements

The Financial Crimes Enforcement Network on May 11 released its long-awaited Final Rule that will require certain financial institutions to “look through” the nominal account holder to identify the account's beneficial owners who own or control (directly or indirectly) certain legal entity customers.

October 1, 2015

Treasury Department Issues Comprehensive Assessment of US Money Laundering and Terrorist Financing Risk

An article co-written by Franca Harris Gutierrez, Sharon Cohen Levin, Andrew R. Golden and Jennifer R. Jacoby, published in the September 2015 edition of Market Solutions, Vol. 24, No. 3.

June 17, 2015

Treasury Department Issues Comprehensive Assessment of US Money Laundering and Terrorist Financing Risk

For the first time in a decade, the Treasury Department has released its own anti–money laundering (AML) and terrorist financing Risk Assessments, which may both set a strategic framework for future AML regulatory developments and establish a baseline expectation for financial institutions’ own AML risk assessments.

May 6, 2015

In Warning to Bitcoin and Other Virtual Currency Businesses, FinCEN Issues First Enforcement Action for Virtual Currency Activity

The US government took its strongest step yet in its oversight of other virtual currency yesterday, fining prominent "Bitcoin alternative" company Ripple Labs Inc. $700,000 for what the government called a willful violation of the anti-money laundering laws.

May 1, 2013

Race-Conscious Charter Schools and the Antibalikinzation Perspective of Equal Protection

An article by Jennifer Jacoby, published in Journal of Constitutional Law, Vol. 15, No. 5, pp. 1561-1580.

Professional Activities

Ms. Jacoby is a member of the Digital Currency & Ledger Defense Coalition, an organization of lawyers and academics founded to protect constitutional rights in connection with digital currency and distributed ledger technology on a pro bono basis.


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JD, University of Pennsylvania Law School, 2013, Author, Journal of Constitutional Law, Co-chair of the Diversity Committee, Penn Law Women's Association, Black Law Students Association

BA, Government, summa cum laude, Connecticut College, 2010, Phi Beta Kappa, Winthrop Scholar, Pi Sigma Alpha

Bar Admissions

District of Columbia

New York

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