Economic Sanctions & Anti-Money Laundering
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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.
- H. Christopher Boehning
- Walter Brown
- Jessica S. Carey
- David Fein
- Michael E. Gertzman
- Roberto J. Gonzalez
- Brad S. Karp
- Mark F. Mendelsohn
- Richard S. Elliott
- Peter Jaffe
- Jacobus J. Schutte
- Colleen Anderson
- Robyn E. Bernstein
- Braeshaun Dozier
- Emily M. Glavin
- Aaron E. Haier
- Alexander K. Harper
- Molly E. Henneberry
- Udi Karklinsky
- Carly Lagrotteria
- Kevin P. Madden
- Marisa A. Papenfuss
- Sylvia Sui
- Joshua R. Thompson
- Andrew H. Trinker
- Courtney Wiesner
- Clay Wild
- Bailey K. Williams
- Taylor C. Williams
- Simona Xu
- Miguel Zamora
- Economic Sanctions & AML
- Cryptocurrency & Blockchain
- White Collar & Regulatory Defense
In this memorandum, we survey 2021 U.S. economic sanctions and anti-money laundering developments and trends, and provide an outlook on 2022. We also provide thoughts on compliance and risk mitigation measures for a potentially challenging regulatory environment.
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.
The Biden Administration’s First Two Weeks of Sweeping Sanctions and Export Controls on Russia/Ukraine
In response to Russia’s invasion of Ukraine, the Biden Administration has put in place a series of sweeping sanctions and export controls affecting Russia, Ukraine, and Belarus. We summarize these actions and outline measures that U.S. and non-U.S. companies may consider to mitigate risk.
President Biden Prohibits “New Investment” in Russia; Additional Russian Companies and Individuals Are Added to SDN List
In a significant expansion of sanctions, President Biden recently issued an executive order prohibiting “new investment” in Russia by U.S. persons, wherever located.
The DOJ recently announced the seizure of a Russian oligarch’s luxury yacht, marking the first seizure by Task Force KleptoCapture, an interagency task force led by the DOJ and focused on enforcing Russian sanctions.
The Biden Administration has warned that it is ramping up efforts to enforce the new and pre-existing Russia/Ukraine sanctions, including by creating a DOJ task force focused on investigating potential violations.
Litigation partner Jessica Carey was quoted in an article in Bloomberg Law on the business community’s response to the Russia sanctions.
Rachel Fiorill Discusses Russia Sanctions and the U.S. Sanctions Regime With Global Association of Risk Professionals
Litigation counsel Rachel Fiorill was quoted extensively in an article published by the Global Association of Risk Professionals concerning the exacerbated compliance burdens and risks businesses face due to the stepped-up economic sanctions against Russia.
Litigation partner Roberto Gonzalez and counsel Rachel Fiorill served as contributing editors of the International Comparative Legal Guide - Sanctions 2022, penning two chapters and the preface.
Brad Karp, Roberto Gonzalez and Hilary Oran Co-Author Law360 Article on CFPB Policy Shift Regarding Abusive Acts
Firm Chairman Brad Karp, litigation partner Roberto Gonzalez and litigation associate Hilary Oran co-authored an article, “What CFPB Policy Shift Means For Scrutiny Of Abusive Acts,” that appeared in Law360.
OFAC Enforcement Action against U.S. Payments Company Shows the Importance of Robust Sanctioned Person and Location Screening
OFAC announced a settlement with the company for allowing persons in sanctioned jurisdictions and on OFAC's SDN List to engage in transactions.
The OCC Issues Guidance Confirming that National Banks and Federal Savings Associations May Hold Reserves for Certain Stablecoins
U.S. banks and federal savings associations may accept deposits that serve as reserves for stablecoin backed on a 1:1 basis by a single fiat currency in a hosted wallet.
Litigation partner Chris Boehning was featured in the latest episode of the Institute of International Bankers’ “Bank Talk” podcast series.
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 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.