Our team advises U.S. and non-U.S. clients across industries on their most sensitive U.S. economic sanctions and Bank Secrecy Act/anti-money laundering (BSA/AML) issues. With our preeminent regulatory defense and white collar experience, we are uniquely positioned to assist clients in responding to regulator inquiries, examinations and subpoenas; conducting internal investigations; and handling matters that develop into multi-agency civil and criminal investigations. Our practice also encompasses regulatory advice, compliance counseling and transactional due diligence.
Publications
FinCEN Issues Rule Imposing AML Requirements on Certain Investment Advisers
The Department of the Treasury’s Financial Crimes Enforcement Network recently issued a final rule imposing expansive new legal obligations on certain investment advisers, requiring them to adopt anti-money laundering (AML) and countering financing of terrorism (CFT) programs, and to report suspicious activities to the government as of the effective date of the rule, January 1, 2026.
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Roberto Gonzalez and Joshua Thompson Publish Two Chapters in ICLG Sanctions 2025
Economic Sanctions & AML Co-Chair Roberto Gonzalez and corporate associate Joshua Thompson served as contributing editors of the International Comparative Legal Guide - Sanctions 2025.
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Economic Sanctions and Anti-Money Laundering Developments: 2023 Year in Review
- Economic Sanctions & AML
- Jarryd E. Anderson
- H. Christopher Boehning
- Walter Brown
- Jessica S. Carey
- John P. Carlin
- David Fein
- Roberto J. Gonzalez
- Brad S. Karp
- Loretta E. Lynch
- Mark F. Mendelsohn
- David K. Kessler
- Nathan Mitchell
- Jacobus J. Schutte
- Jennifer Gilbert
- Samuel Kleiner
- Anna P. Lipin
- Kevin P. Madden
- Sean S. Malone
- Jordan E. Orosz
- Shekida A. Smith-Sandy
- Joshua R. Thompson
- Griffin Varner
- Jacob Wellner
- Sarah Calderone
- Ridan R. Cunningham
- Litigation
- Cryptocurrency & Blockchain
- White Collar & Regulatory Defense
- Investigations
This memorandum surveys U.S. economic sanctions and anti-money laundering developments in 2023 and provides an outlook for 2024. We also outline considerations for companies to strengthen their compliance in this dynamic environment.
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OFAC Issues New Regulations Addressing Non-Public “Tailored Actions” and Lengthening Recordkeeping Requirements
- L. Rush Atkinson
- Jessica S. Carey
- John P. Carlin
- Roberto J. Gonzalez
- Brad S. Karp
- Loretta E. Lynch
- Mark F. Mendelsohn
- Jacobus J. Schutte
- Nicole Succar
- Samuel Kleiner
- Nathan Mitchell
- Neil Chitrao
- Sean S. Malone
- Joshua R. Thompson
- Economic Sanctions & AML
- National Security, CFIUS & FARA
- Corporate
- Financial Services
- Finance
The U.S. Treasury Department's Office of Foreign Assets Control has issued updated regulations that will have significant implications for companies subject to U.S. jurisdiction, including financial institutions.
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Roberto Gonzalez to Moderate Panel on Financial Institutions’ Compliance With Sanctions Against Russia at ACI Sanctions Conference
Economic Sanctions & AML Co-Chair Roberto Gonzalez will moderate a panel at the 18th annual ACI Sanctions Conference.
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The U.S. Expands Economic Measures Targeting Russia, and the G-7 Announces Ukraine Loan Backed by Immobilized Russian Sovereign Assets
- L. Rush Atkinson
- H. Christopher Boehning
- Walter Brown
- Jessica S. Carey
- John P. Carlin
- Roberto Finzi
- Roberto J. Gonzalez
- Melinda Haag
- Brad S. Karp
- Loretta E. Lynch
- Mark F. Mendelsohn
- Jacobus J. Schutte
- David K. Kessler
- Samuel Kleiner
- Justin D. Lerer
- Sean S. Malone
- César Rivière
- Joshua R. Thompson
- Jacob Wellner
- Economic Sanctions & AML
- National Security, CFIUS & FARA
- International Arbitration
- Financial Services Litigation & Investigations
On June 12, in the lead-up to the G-7 summit, the United States imposed new sanctions and export control measures targeting Russia.
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Sam Kleiner to Moderate Panel on Financial Crime Compliance in the Digital Asset Space at ABA International Law Conference
Litigation counsel Sam Kleiner will moderate a panel, “A Season of Change: AML and Sanctions Convergence in the Regulation of Digital Assets,” as part of the American Bar Association’s International Law Section’s 2024 Annual Conference.
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Roberto Gonzalez to Co-Chair ACI’s New York Forum on Economic Sanctions and Moderate Panel on Sanctions Evasion
Economic Sanctions & AML Co-Head Roberto Gonzalez will co-chair the New York Forum on Economic Sanctions hosted by the American Conference Institute.
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Roberto Gonzalez and Joshua Thompson Author Two Chapters in ICLG Sanctions 2024
Litigation partner Roberto Gonzalez and corporate associate Joshua Thompson served as contributing editors of the International Comparative Legal Guide - Sanctions 2024.
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Jessica Carey Discusses Career Highlights and New Litigation Developments in Benchmark Litigation Q+A
In a wide-ranging interview published on October 24, Litigation Department Co-Chair Jessica Carey spoke with Benchmark Litigation about her career, recent client achievements, and emerging areas of focus for our firm’s litigators.
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Roberto Gonzalez to Discuss Strategies for Establishing Effective Sanctions Programs at Pharmaceutical Compliance Event
Economic Sanctions & AML Co-Chair Roberto Gonzalez will participate in a panel, “Sanctions – Compliance Monitoring Approaches and Tools,” as part of the 24th Annual Pharmaceutical and Medical Device Ethics and Compliance Congress.
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Roberto Gonzalez to Discuss Current Trends in International Sanctions Compliance at Global Legal Group Webinar
Litigation partner Roberto Gonzalez will participate in a webinar, “Current Trends in International Sanctions Compliance,” hosted by Global Legal Group in partnership with The International Comparative Legal Guides and The Association of Governance Risk & Compliance.
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First Cases From DOJ’s Disruptive Technology Strike Force Cover Export Control Evasion and Trade Secret Theft
The U.S. Department of Justice recently announced the first five criminal cases brought by the new Disruptive Technology Strike Force (DTSF). The cases underscore the DTSF’s wide-ranging focus.
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DOJ and OFAC Reach Historic Resolutions With British American Tobacco for North Korea Sanctions Violations
- H. Christopher Boehning
- Jessica S. Carey
- John P. Carlin
- David Fein
- Roberto J. Gonzalez
- Brad S. Karp
- Mark F. Mendelsohn
- David K. Kessler
- Joshua R. Thompson
- Economic Sanctions & AML
- Mergers & Acquisitions
- Anti-Corruption & FCPA
- Cybersecurity & Data Protection
- Internal Investigations
- Mergers & Acquisitions Litigation
- White Collar & Regulatory Defense
The U.S. Department of Justice and the U.S. Department of Treasury Office of Foreign Assets Control (OFAC) recently reached resolutions with British American Tobacco and its Singaporean subsidiary to resolve charges of bank fraud and North Korea sanctions violations.
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Events
John Carlin Discusses New Outbound Investment Executive Order at U.S.-China Business Council
Cybersecurity & Data Privacy Co-Chair John Carlin participated in a panel discussion, “President Biden’s Executive Order on Outbound Investment,” hosted by The U.S.-China Business Council on August 17.
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