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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

Roberto Gonzalez and Rachel Fiorill Author USA Chapter for ICLG’s Inaugural Comparative Guide to Sanctions

Litigation partner Roberto Gonzalez and counsel Rachel Fiorill served as contributing editors and authored two chapters for the inaugural edition of The International Comparative Legal Guide (ICLG) to: Sanctions 2020, published by the Global Legal Group Ltd., London.

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Publications

OFAC Reaches Settlement Agreement with U.K. Bank for Complex Payment Structures Used to Circumvent U.S. Sanctions

On September 17, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $4,000,000 settlement agreement with the British Arab Commercial Bank plc (“BACB”), a commercial bank located in the United Kingdom, for apparent violations of OFAC’s Sudanese Sanctions Regulations (“SSR”).

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White papers

Cryptocurrencies & Blockchain

The sudden and rapid rise of virtual currencies, coupled with the potential applications of blockchain and distributed ledger technologies across virtually all industries, has generated a wave of innovation, disruptive businesses and a modern digital economy. This series of white papers examines the new legal and regulatory issues in these areas that are cropping up every day.

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Publications

Does President Trump Have Authority to Force U.S. Companies to Leave China?

On August 23, 2019, President Trump tweeted that “American companies are hereby ordered to immediately start looking for an alternative to China, including bringing. . .your companies [home] and making products in the USA.” In further tweets, the President raised a series of grievances with China, including intellectual property theft, and ordered several U.S. companies to begin searching for and refusing all deliveries of fentanyl from China.

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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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