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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

D.C. Circuit Upholds Decision Requiring Three Chinese Banks to Produce Documents Located in China to the U.S. Government

On July 30, 2019, the U.S. Court of Appeals for the District of Columbia affirmed civil contempt orders by the D.C. District Court against three Chinese banks for their failure to produce documents in response to U.S. government subpoenas relating to an investigation of North Korea’s financing of its nuclear weapons program.

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Publications

UniCredit Group Banks Agree to Pay a Combined $1.3 Billion Penalty for Iranian and Other Sanctions Violations; One Bank Pleads Guilty

On April 15, 2019, UniCredit Bank AG (“UCB AG”), headquartered in Munich, Germany, UniCredit Bank Austria AG (“Bank Austria”), headquartered in Vienna, Austria, and their corporate parent, UniCredit S.p.A., an Italian global banking and financial services company (collectively the “UniCredit Group”), resolved alleged violations of U.S. economic sanctions with federal and state agencies for a combined $1.3 billion payment and the imposition of a monitor.

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Events

Paul, Weiss Co-Hosts Panel Discussion With China General Chamber of Commerce USA

On June 25, Paul, Weiss co-hosted an event with the China General Chamber of Commerce USA (CGCC), “Detecting and Reporting Suspicious Transactions and Preventing Sanctions Violations.”

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Publications

New York DFS Creates New “Powerhouse” Division Combining the Enforcement Division and Financial Frauds and Consumer Protection Division

On April 29, 2019, Linda Lacewell, the Acting Superintendent of the New York State Department of Financial Services (“DFS”), announced the combination of DFS’s previously separate Enforcement Division and Financial Frauds and Consumer Protection Division into a newly created Consumer Protection and Financial Enforcement Division. 

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Events

Jessica Carey to Deliver Keynote Address at Annual Compliance & Investigations Conference

Litigation partner Jessica Carey will deliver the keynote address at Gleiss Lutz’s annual Compliance & Investigations conference.

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Publications

OFAC Issues Guidance on Sanctions Compliance Programs and Flags “Root Causes” Underlying Prior Enforcement Actions

On May 2, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued guidance entitled “A Framework for OFAC Compliance Commitments” (the “Framework”), that strongly encourages companies to “develop, implement, and routinely update” a risk-based sanctions compliance programs (“SCPs”). 

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Videos

Economic Sanctions and Anti-Money Laundering Developments: 2017 Year in Review

In this video, litigation partners Mike Gertzman, Jessica Carey and Roberto Gonzalez and counsel Rachel Fiorill offer guidance for bolstering compliance as they discuss recent developments in sanctions and AML policy and enforcement.

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