Economic Sanctions & Anti-Money Laundering
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.
Litigation partner Roberto Gonzalez moderated a panel, “Sanctions and Security: What’s New at OFAC in 2020,” as part of the Institute of International Bankers’ two-day virtual seminar.
President Trump Signs the Hong Kong Autonomy Act into Law and Issues an Implementing Executive Order
President Trump recently signed the Hong Kong Autonomy Act (HKAA) into law and issued an executive order implementing the HKAA.
The UK Financial Conduct Authority recently ordered Commerzbank to pay more than £37 million penalty for years of anti-money laundering failures in systems and controls. This action reinforces the importance of ensuring that expectations of financial system regulators are met, and that any issues that are identified are promptly addressed. In particular, regulators remain focused on ensuring that banks devote sufficient resources to AML compliance, formally document and clearly define roles and responsibilities for AML compliance programs, and appropriately calibrate transaction monitoring systems to monitor potentially suspicious transactions.
Industrial Bank of Korea Reaches $86 Million AML Resolution with DOJ, NY Attorney General, and NY DFS
The DOJ, the N.Y. Attorney General and the N.Y. Department of Financial Services (DFS) recently announced an $86 million resolution with Industrial Bank of Korea (IBK) in connection with criminal violations of the Bank Secrecy Act and violations of New York’s banking laws.
OFAC Cites the Use of U.S.-Origin Software and U.S. Network Infrastructure in Reaching a Nearly $8 Million Settlement with a Swiss Commercial Aviation Services Company
The U.S. Treasury Department’s Office of Foreign Assets Control has announced a $7,829,640 settlement agreement with Geneva-based Société Internationale de Télécommunications Aéronautiques.
- Financial Institutions
- Economic Sanctions & AML
- Supreme Court & Appellate Litigation
- H. Christopher Boehning
- Jessica S. Carey
- Christopher D. Frey
- Michael E. Gertzman
- Roberto J. Gonzalez
- Brad S. Karp
- Richard S. Elliott
- Rachel Fiorill
- Karen R. King
- Robyn E. Bernstein
- Theodore M. Galanakis
- Udi Karklinsky
- Sofia D. Martos
- Mariah N. Rivera
- Jacobus J. Schutte
- Katherine S. Stewart
- Sylvia Sui
- Joshua R. Thompson
- Apeksha S. Vora
- Bailey K. Williams
- Jacob A. Braly
This memorandum surveys economic sanctions and anti-money laundering (“AML”) developments and trends in 2019 and provides an outlook for the year ahead.
OCC Takes Unprecedented Enforcement Actions Against Eight Former Wells Fargo Executives, Including the Former Chairman & CEO, Head of the Bank, General Counsel, and Risk and Audit Executives
As the latest chapter in the aftermath of the Wells Fargo fake accounts scandal, the OCC announced enforcement actions against eight former Wells Fargo executives for their roles in the bank’s “systemic sales practices misconduct.”
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.
DOJ Announces Revised Export Control and Sanctions Enforcement Policy for Companies, Including Financial Institutions
The U.S. Department of Justice’s National Security Division recently announced a revised policy designed to encourage companies, including financial institutions, to make voluntary self-disclosures to the DOJ in connection with potentially willful export control and economic sanctions violations.
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”).
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.