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. 

Update on U.S. Sanctions 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).

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U.S. Sanctions Relating to Russia and Ukraine: Navigating the Current Landscape

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.

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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

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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.

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OFAC Breaks New Ground By Penalizing Non-U.S. Companies for Making U.S. Dollar Payments Involving a Sanctioned Country

On July 27, 2017,  the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $12 million settlement with two Singapore-based companies over their use of U.S. dollar payments in connection with providing telecommunications systems to Iran.  It marks the first time OFAC has penalized a non-U.S., non-financial company for using U.S. dollar payments involving a sanctioned country.  OFAC found that the Singapore-based companies caused various banks to violate OFAC regulations by processing these payments through the U.S. financial system.  In this memorandum, we examine the action’s implications for non-U.S. companies doing business involving OFAC-sanctioned jurisdictions or parties, and we offer recommendations for reducing the risk of OFAC liability.

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President Trump Signs Sanctions Legislation Targeting Russia, North Korea and Iran, Creating New Compliance Risks for U.S. and Non-U.S. Companies

President Trump recently signed into law H.R. 3364, the “Countering America’s Adversaries Through Sanctions Act.” The law significantly expands U.S. sanctions targeting Russia and restricts President Trump’s ability to lift them unilaterally. It also adds sanctions targeting North Korea and codifies certain sanctions against Iran. In this memorandum, we describe the new law, which heightens risk for U.S. and non-U.S. companies conducting business with Russia, North Korea and Iran, and outline considerations for companies seeking to mitigate their risks under the new legislation.   

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