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
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
- Michael E. Gertzman
- Roberto J. Gonzalez
- Brad S. Karp
- Mark F. Mendelsohn
- Richard S. Elliott
- David Kessler
- Kelsey E. Sweeney
- 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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Publications
John Carlin Discusses Increased Sanctions Compliance Pressure on Private Sector With Reuters
Litigation partner John Carlin spoke with Reuters about the expected surge in sanctions and export control enforcement as the U.S. government leans on economic tools to counter global adversaries.
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BIS Imposes $300 Million Penalty Against Seagate and Makes Controversial Changes to Voluntary Self-Disclosure Program
- H. Christopher Boehning
- Jessica S. Carey
- John P. Carlin
- David Fein
- Michael E. Gertzman
- Roberto J. Gonzalez
- Brad S. Karp
- Richard S. Elliott
- 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 Commerce’s Bureau of Industry and Security (BIS) imposed a $300 million civil penalty to resolve alleged violations of U.S. export controls involving sales to a Chinese company on the Entity List.
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EVENTS
Roberto Gonzalez to Moderate Panel with Justice, Commerce and Treasury Officials on Russian Sanctions Evasion
Litigation partner Roberto Gonzalez, will moderate a panel, “KleptoCapture Task Force: Status Report on Catching Sanctions Evaders and Seizing Russian Oligarchs' Assets,” as part of the American Conference Institute's sanctions conference on April 26 in Washington, D.C.
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PUBLICATIONS
OFAC and BIS Announce Expansive New Sanctions and Export Controls Targeting Russia and Belarus
- H. Christopher Boehning
- Jessica S. Carey
- John P. Carlin
- David Fein
- Michael E. Gertzman
- Roberto J. Gonzalez
- Brad S. Karp
- Richard S. Elliott
- David Kessler
- Joshua R. Thompson
- Economic Sanctions & AML
- Mergers & Acquisitions
- Anti-Corruption & FCPA
- Cybersecurity & Data Protection
- Internal Investigations
- Mergers & Acquisitions Litigation
- White Collar & Regulatory Defense
On the one-year anniversary of Russia’s invasion of Ukraine, the U.S. government announced a new wave of sweeping sanctions and export controls targeting Russia as well as Belarus for its role in continuing to support Russia’s invasion of Ukraine.
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Publications
Economic Sanctions and Anti-Money Laundering Developments: 2022 Year in Review
- H. Christopher Boehning
- Walter Brown
- Jessica S. Carey
- John P. Carlin
- David Fein
- Michael E. Gertzman
- Roberto J. Gonzalez
- Brad S. Karp
- Mark F. Mendelsohn
- Richard S. Elliott
- David Kessler
- Jacobus J. Schutte
- Neil Chitrao
- Jennifer K. Corcoran
- Ridan R. Cunningham
- Braeshaun Dozier
- Marissa A. Piccolo
- Morgan J. Sandhu
- Jake E. Struebing
- Joshua R. Thompson
- Griffin Varner
- Alicia Walker
- Economic Sanctions & AML
- Litigation
- Cryptocurrency & Blockchain
- White Collar & Regulatory Defense
This memorandum surveys U.S. economic sanctions and anti-money laundering developments and trends in 2022 and provides an outlook for 2023.
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DOJ and FinCEN Take Coordinated Action Against Bitzlato Cryptocurrency Exchange and Its Owner
In the first order of its kind, the U.S. Department of the Treasury’s FinCEN identified global cryptocurrency exchange Bitzlato as a “primary money laundering concern” under the Combating Russian Money Laundering Act.
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John Carlin to Discuss Trajectory of Regulations and Enforcement at Kharon Global Summit
Litigation partner John Carlin will participate in a panel, “Policy Outlook: Discussions on the Trajectory of Regulations & Enforcement,” as part of the 2023 Kharon Global Summit.
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OFAC Enforcement Action Targets U.S.-Incorporated Cryptocurrency Exchange for Apparent Violations of U.S. Sanctions
The U.S. Treasury’s Office of Foreign Assets Control recently reached a monetary settlement with U.S.-incorporated cryptocurrency exchange Payward, Inc., popularly known as Kraken, over apparent sanctions violations in connection with several hundred transactions processed by Kraken on behalf of individuals located in Iran.
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DOJ Prosecutions Reflect Aggressive Stance Toward Russian Sanctions and Export Control Evasion
- H. Christopher Boehning
- Walter Brown
- Jessica S. Carey
- John P. Carlin
- David Fein
- Michael E. Gertzman
- Roberto J. Gonzalez
- Brad S. Karp
- Loretta E. Lynch
- Mark F. Mendelsohn
- Peter Jaffe
- David Kessler
- Joshua R. Thompson
- Economic Sanctions & AML
- Mergers & Acquisitions
- Anti-Corruption & FCPA
- Cybersecurity & Data Protection
- Internal Investigations
- Mergers & Acquisitions Litigation
- White Collar & Regulatory Defense
Two U.S. Attorneys’ offices, in coordination with the DOJ’s Task Force KleptoCapture, charged multiple individuals and corporate entities with participating in schemes to evade U.S. sanctions and export controls applicable to Russia.
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David Kessler Discusses Recent Developments Related to Financial Crimes and Corporate Criminal Enforcement in NYSBA Webinar
Litigation counsel David Kessler spoke in a New York State Bar Association webinar, “Financial Regulation/Money Laundering Hot Topics,” on May 11.
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Jessica Carey to Speak on Institute of International Bankers Panel on Suspicious Activity Reports
Litigation partner Jessica Carey will participate in the panel “A Case Study in SARs Writing” as part of the Institute of International Bankers’ annual Anti-Money Laundering Seminar.
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Roberto Gonzalez and Joshua Thompson Author Two Chapters in ICLG Sanctions 2023
Litigation partner Roberto Gonzalez and associate Joshua Thompson served as contributing editors of the International Comparative Legal Guide - Sanctions 2023, which is the fourth edition of this handbook.
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David Fein to Discuss the Effectiveness of Financial Crime Detection Policy
Litigation special counsel David Fein will co-introduce a research presentation, “‘314(b) Effectiveness’ Policy Discussion,” and moderate a subsequent Q&A.
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Treasury Escalates Russia Sanctions, Including New Prohibition on the Provision of Certain Services
The United States increased pressure on Russia to de-escalate its conflict in Ukraine through new sanctions targeting individuals and entities critical to Russia’s war efforts, as well as against the provision of accounting, trust and corporate formation, and management consulting services to Russia.
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