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

UniCredit Group Banks Agree to Pay a Combined $1.3 Billion Penalty for Iranian and Other Sanctions Violations; One Bank Pleads Guilty

On April 15, 2019, UniCredit Bank AG (“UCB AG”), headquartered in Munich, Germany, UniCredit Bank Austria AG (“Bank Austria”), headquartered in Vienna, Austria, and their corporate parent, UniCredit S.p.A., an Italian global banking and financial services company (collectively the “UniCredit Group”), resolved alleged violations of U.S. economic sanctions with federal and state agencies for a combined $1.3 billion payment and the imposition of a monitor.

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Videos

Economic Sanctions and Anti-Money Laundering Developments: 2017 Year in Review

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.

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Videos

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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Publications

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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Publications

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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Publications

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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