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.
OFAC Reaches Settlement with Cobham Holdings, Inc. for Violations Resulting from Deficient Screening Software
On November 27, 2018, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced a nearly $90,000 settlement agreement with Virginia-based Cobham Holdings, Inc. (“Cobham”), a global provider of technology and services in aviation, electronics, communications, and defense, on behalf of its former subsidiary, Aeroflex/Metelics, Inc. (“Metelics”).
On May 8, President Trump announced the unilateral withdrawal of the United States from the Iran nuclear deal, the Joint Comprehensive Plan of Action.
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.
Recent months have witnessed important developments in the U.S. sanctions landscape, including new legislation, executive actions, and an uptick in enforcement by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC).
- Economic Sanctions & AML
- Financial Institutions
- White Collar & Regulatory Defense
- H. Christopher Boehning
- Jessica S. Carey
- Michael E. Gertzman
- Roberto J. Gonzalez
- Brad S. Karp
- Richard S. Elliott
- Rachel Fiorill
- Karen R. King
- Kamil Ammari
- Matthew J. Carhart
- Evan J. Meyerson
- Jacobus J. Schutte
- James R. Simmons Jr.
- Anand Sithian
- Katherine S. Stewart
- Kaveri Vaid
Economic sanctions and anti-money laundering remain top U.S. regulatory priorities, with federal and state agencies imposing over $2.5 billion in penalties in 2017.
In light of the recent changes and increasing complexity in Russia/Ukraine-related sanctions, this memorandum provides an overview of the sanctions program as it exists today, focusing on both primary sanctions restrictions and secondary sanctions authorities. We also outline considerations for both U.S. and non-U.S. companies seeking to manage their sanctions risk.
President Trump Announces Intent to “De-Certify” Iran’s Compliance with the Joint Comprehensive Plan of Action
President Trump announced that he will not certify Iran’s compliance with the Joint Comprehensive Plan of Action, the multi-lateral commitment under which the United States, European Union, and five other countries agreed to lift certain economic sanctions against Iran in exchange for Iran’s implementation of certain nuclear-related commitments
President Trump Signs Executive Order Authorizing Sweeping Secondary Sanctions on Entities Involved in North Korean Trade
On September 21, President Trump signed an executive order authorizing the Treasury Department to impose secondary sanctions against individuals and entities, including non-U.S. financial institutions, for conducting or facilitating trade with North Korea. In this memorandum, we describe the order’s significant provisions and the Trump Administration's related efforts to pressure the North Korean regime.