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.
Roberto Gonzalez and Karen King to Speak at 2017 Chinese Financial Institutions’ Anti-Money Laundering and Sanctions Compliance Forum in New York
On December 12, Roberto Gonzalez and Karen King will be guest speakers at the 2017 Chinese Financial Institutions’ Anti-Money Laundering and Sanctions Compliance Forum, sponsored by Ernst & Young and the China General Chamber of Commerce-USA. The event is being held at Bank of China, and senior management from the New York branches of major Chinese (and some Taiwanese) banks will be in attendance. Roberto is speaking on the panel “Understanding Economic Sanctions and the Global Impacts of US Actions.” Karen will be speaking on the panel “FinCrime/Sanctions Technology Challenges and DFS 504.” Paul, Weiss is the only law firm speaking at the forum.
Events & Publications
Karen King to Speak at Annual APAC NYC Conference
- Apr 29, 2019
- Events
Karen King to Speak at Annual APAC NYC Conference
Litigation counsel Karen King will speak on a panel at Consilio’s 3rd Annual Asia-Pacific New York City conference, “Caught in the Crossfire: Navigating Regulatory, Transactional and Litigation Risks in Light of Current U.S.-China…
Jessica Carey to Deliver Keynote Address at Annual Compliance & Investigations Conference
- Apr 11, 2019
- Events
Jessica Carey to Deliver Keynote Address at Annual Compliance & Investigations Conference
Litigation partner Jessica Carey will deliver the keynote address at Gleiss Lutz’s annual Compliance & Investigations conference.
OFAC Takes Enforcement Action Against U.S. Parent Company for its Recently Acquired Chinese Subsidiary’s Iran Sanctions Violations
- Apr 01, 2019
- Publications
OFAC Takes Enforcement Action Against U.S. Parent Company for its Recently Acquired Chinese Subsidiary’s Iran Sanctions Violations
On March 27, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $1,869,144 settlement agreement with Connecticut-based Stanley Black & Decker, Inc. (“Stanley Black & Decker”), a…
In Unprecedented Move, OFAC Takes Enforcement Action Against U.S. Parent Company for Turkish Subsidiary’s Iran Sanctions Violations and Simultaneously Sanctions the Subsidiary’s Ex-Managing Director
- Feb 11, 2019
- Publications
In Unprecedented Move, OFAC Takes Enforcement Action Against U.S. Parent Company for Turkish Subsidiary’s Iran Sanctions Violations and Simultaneously Sanctions the Subsidiary’s Ex-Managing Director
On February 7, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $13,381 settlement agreement with Virginia-based Kollmorgen Corporation (“Kollmorgen”), a technology and manufacturing…
Economic Sanctions and Anti-Money Laundering Developments: 2018 Year in Review
- Feb 05, 2019
- Publications
Economic Sanctions and Anti-Money Laundering Developments: 2018 Year in Review
This memo surveys economic sanctions and AML developments and trends in 2018 and provides an outlook for the year ahead. We also provide some thoughts concerning compliance and risk mitigation in this challenging environment.
OFAC Reaches Settlement with e.l.f. Cosmetics, Inc. for North Korea Sanctions Violations Resulting from Inadequate Supply Chain Due Diligence
- Feb 04, 2019
- Publications
OFAC Reaches Settlement with e.l.f. Cosmetics, Inc. for North Korea Sanctions Violations Resulting from Inadequate Supply Chain Due Diligence
On January 31, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced a $996,080 settlement agreement with California-based e.l.f. Cosmetics, Inc. (“ELF”), to settle its potential civil liability for …
Christopher D. Frey to Participate in Anti-Money Laundering Conference
- Feb 08, 2019
- Events
Christopher D. Frey to Participate in Anti-Money Laundering Conference
Litigation partner Chris Frey will participate in the “2019 Anti-Money Laundering Conference: Accelerating Implementation of a Risk Based Approach in Preparation for the Fourth FATF Mutual Evaluation of Japan,” sponsored by GoodWay,…
FCPA Enforcement and Anti-Corruption Developments: 2018 Year in Review
- Jan 17, 2019
- Publications
FCPA Enforcement and Anti-Corruption Developments: 2018 Year in Review
In this memo, we offer reflections on the year’s most significant developments in anti-corruption and FCPA enforcement and policy.
Court Upholds SEC Authority and Finds Broker-Dealer Liable for Thousands of Suspicious Activity Reporting Violations
- Jan 07, 2019
- Publications
Court Upholds SEC Authority and Finds Broker-Dealer Liable for Thousands of Suspicious Activity Reporting Violations
On December 11, 2018, the Securities and Exchange Commission (SEC) obtained a victory in its enforcement action against Alpine Securities Corporation, a broker that cleared transactions for microcap securities that were allegedly used …
OFAC Reaches Settlement with Cobham Holdings, Inc. for Violations Resulting from Deficient Screening Software
- Nov 29, 2018
- Publications
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…
CFIUS Adopts Pilot Program that Imposes Mandatory Filing Requirement for Foreign Acquisitions and Investments Involving Critical Technology in Certain Industry Sectors
- Oct 26, 2018
- Publications
CFIUS Adopts Pilot Program that Imposes Mandatory Filing Requirement for Foreign Acquisitions and Investments Involving Critical Technology in Certain Industry Sectors
On October 10, 2018, the Treasury Department announced that the interagency Committee on Foreign Investment in the United States (“CFIUS”) had used its new authority under the Foreign Investment Risk Review Modernization Act of 2018…
Brad Karp Featured in LEADERS Magazine
- Oct 10, 2018
- Publications
Brad Karp Featured in LEADERS Magazine
Firm chairman Brad Karp was featured in a Q&A in the latest issue of LEADERS magazine.
The Financial Crisis 10 Years Later: Lessons Learned
- Sep 15, 2018
- Publications
The Financial Crisis 10 Years Later: Lessons Learned
Ten years after the collapse of Lehman Brothers, market participants and other global companies operate in a markedly changed regulatory enforcement and compliance landscape. This memorandum discusses the legal and business…
President Trump Withdraws the United States from the Iran Nuclear Deal
- May 09, 2018
- Publications
President Trump Withdraws the United States from the Iran Nuclear Deal
On May 8, President Trump announced the unilateral withdrawal of the United States from the Iran nuclear deal, the Joint Comprehensive Plan of Action.
FCPA Enforcement and Anti-Corruption Developments: Q1 2018
- Apr 13, 2018
- Publications
FCPA Enforcement and Anti-Corruption Developments: Q1 2018
The first quarter of 2018 saw a flurry of declinations of FCPA prosecutions by the DOJ and the SEC, and only one FCPA corporate enforcement resolution by the DOJ and two resolutions by the SEC.
Trump Administration Imposes New Sanctions on Russian Oligarchs and Government Officials
- Apr 10, 2018
- Publications
Trump Administration Imposes New Sanctions on Russian Oligarchs and Government Officials
On April 6, 2018, the Trump administration imposed new sanctions on 7 Russian oligarchs, 12 companies they own or control, 17 Russian government officials, and a state-owned Russian weapons trading company and its subsidiary, a…
Roberto Gonzalez and Rachel Fiorill to Speak at ACI Economic Sanctions Conference
- Apr 25, 2018
- Events
Roberto Gonzalez and Rachel Fiorill to Speak at ACI Economic Sanctions Conference
Litigation partner Roberto Gonzalez and counsel Rachel Fiorill will speak on panels at ACI’s 11th Annual Advanced Forum on Economic Sanctions Enforcement and Compliance.
Economic Sanctions and Anti-Money Laundering Developments: 2017 Year in Review
- Mar 27, 2018
- 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.
Roberto Gonzalez to Participate in AIC’s Chief Compliance Officers Working Group Meeting
- Mar 13, 2018
- Events
Roberto Gonzalez to Participate in AIC’s Chief Compliance Officers Working Group Meeting
Litigation partner Roberto Gonzalez will speak on a panel at the American Investment Council’s (AIC) Chief Compliance Officers Working Group Meeting.
U.S. Bancorp Enters into Deferred Prosecution Agreement and Related Resolutions and Agrees to Pay $613 million for BSA/AML Failures
- Feb 21, 2018
- Publications
U.S. Bancorp Enters into Deferred Prosecution Agreement and Related Resolutions and Agrees to Pay $613 million for BSA/AML Failures
A week after the announcement of a guilty plea and penalty related to Rabobank N.A.’s anti-money laundering violations, the DOJ announced on February 15 that it had entered into a deferred prosecution agreement with U.S. Bancorp,…
Increasing Regulatory Focus on Reforming Financial Institution Culture and Addressing Employee Misconduct Risk
- Feb 21, 2018
- Publications
Increasing Regulatory Focus on Reforming Financial Institution Culture and Addressing Employee Misconduct Risk
Since the financial crisis—and more recently in the wake of the Wells Fargo sales practices scandal and the benchmark manipulation enforcement actions—bank regulators in the United States and around the world have become increasingly…
Rabobank Pleads Guilty to Obstructing OCC Supervision and Agrees to Pay $368 Million for Permitting and Concealing BSA/AML Failures
- Feb 13, 2018
- Publications
Rabobank Pleads Guilty to Obstructing OCC Supervision and Agrees to Pay $368 Million for Permitting and Concealing BSA/AML Failures
The DOJ and the Office of the Comptroller of the Currency recently imposed a $368 million penalty on the U.S. subsidiary of Dutch-based Rabobank. The bank also pleaded guilty to conspiracy to obstruct regulatory oversight of its Bank …
Implications of the Federal Reserve’s Enforcement Action Against Wells Fargo
- Feb 12, 2018
- Publications
Implications of the Federal Reserve’s Enforcement Action Against Wells Fargo
On February 2, 2018, the Federal Reserve Board issued an unprecedented enforcement action against Wells Fargo & Company, prohibiting its asset growth until improvements in board oversight and firmwide risk management systems are…
Second Circuit Vacates and Remands Judgment against Arab Bank in Antiterrorism Act Lawsuit
- Feb 12, 2018
- Publications
Second Circuit Vacates and Remands Judgment against Arab Bank in Antiterrorism Act Lawsuit
On February 9, 2018, the United States Court of Appeals for the Second Circuit handed down a decision recognizing important limitations on the scope of the Antiterrorism Act (“ATA”).
Treasury Department Releases Report Listing Russian Senior Political Figures and Oligarchs
- Feb 05, 2018
- Publications
Treasury Department Releases Report Listing Russian Senior Political Figures and Oligarchs
On January 29, 2018, the Treasury Department submitted to Congress a report pursuant to Section 241 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”).
Economic Sanctions and Anti-Money Laundering Developments: 2017 Year in Review
- Jan 23, 2018
- Publications
Economic Sanctions and Anti-Money Laundering Developments: 2017 Year in Review
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.
FCPA Enforcement and Anti-Corruption Developments: 2017 Year In Review
- Jan 19, 2018
- Publications
FCPA Enforcement and Anti-Corruption Developments: 2017 Year In Review
Despite significant FCPA enforcement activity in 2017, the Trump administration’s approach to enforcement remains elusive and not readily characterized. While actions against individuals were at the highest level in recent years,…
New York DFS Issues $11 Million Fine for AML Deficiencies
- Jan 05, 2018
- Publications
New York DFS Issues $11 Million Fine for AML Deficiencies
The New York Department of Financial Services recently announced a consent order and imposed an $11 million penalty against a major Korean bank, NongHyup Bank, and its New York branch for repeatedly failing to maintain an adequate…
Richard Elliott to Speak at ACI’s 4th National Forum on CFIUS & Team Telecom
- Jan 31, 2018
- Events
Richard Elliott to Speak at ACI’s 4th National Forum on CFIUS & Team Telecom
International trade counsel Richard Elliott will speak on a panel at the American Conference Institute’s (ACI) 4th National Forum on The Committee on Foreign Investment in the United States (CFIUS) & Team Telecom.
U.S. Sanctions Relating to Russia and Ukraine: Navigating the Current Landscape
- Dec 20, 2017
- 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…
Roberto Gonzalez and Karen King to Speak at 2017 Chinese Financial Institutions’ Anti-Money Laundering and Sanctions Compliance Forum in New York
- Dec 12, 2017
- Events
Roberto Gonzalez and Karen King to Speak at 2017 Chinese Financial Institutions’ Anti-Money Laundering and Sanctions Compliance Forum in New York
On December 12, Roberto Gonzalez and Karen King will be guest speakers at the 2017 Chinese Financial Institutions’ Anti-Money Laundering and Sanctions Compliance Forum, sponsored by Ernst & Young and the China General Chamber of…
Update on U.S. Sanctions Policy and Enforcement
- Dec 06, 2017
- 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).
President Trump Announces Intent to “De-Certify” Iran’s Compliance with the Joint Comprehensive Plan of Action
- Oct 13, 2017
- 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…
President Trump Signs Executive Order Authorizing Sweeping Secondary Sanctions on Entities Involved in North Korean Trade
- Sep 26, 2017
- 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…
New York DFS Pursues $630 Million Fine Against Bank for Alleged Anti-Money Laundering and Sanctions Compliance Failures
- Aug 30, 2017
- Publications
New York DFS Pursues $630 Million Fine Against Bank for Alleged Anti-Money Laundering and Sanctions Compliance Failures
The New York State Department of Financial Services (DFS) recently announced that it seeks to impose a nearly $630 million civil penalty against a non-U.S. bank and its New York branch for alleged persistent anti-money laundering and …
President Trump Signs Sanctions Legislation Targeting Russia, North Korea and Iran, Creating New Compliance Risks for U.S. and Non-U.S. Companies
- Aug 03, 2017
- Publications
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…
OFAC Breaks New Ground By Penalizing Non-U.S. Companies for Making U.S. Dollar Payments Involving a Sanctioned Country
- Jul 28, 2017
- Publications
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…
Second Circuit Rejects District Court’s Attempt to Scrutinize DPA
- Jul 18, 2017
- Publications
Second Circuit Rejects District Court’s Attempt to Scrutinize DPA
For the second time in two years, a federal appeals court has rejected a district court’s attempt to scrutinize a deferred prosecution agreement. The July 12 decision in U.S. v. HSBC Bank resolves, at least in the Second Circuit, the…
Client Alert: The Regulatory and Enforcement Outlook for Financial Institutions in 2017
- Feb 22, 2017
- Publications
Client Alert: The Regulatory and Enforcement Outlook for Financial Institutions in 2017
Economic sanctions, anti-money laundering and cybersecurity remain at the forefront of U.S. regulatory priorities. In this memorandum, we survey major developments and trends in these areas in 2016 and early 2017 and provide an…
Client Alert: Treasury and Federal Banking Agencies Clarify BSA/AML and Sanctions Enforcement Standards for Foreign Correspondent Banking Relationships
- Sep 01, 2016
- Publications
Client Alert: Treasury and Federal Banking Agencies Clarify BSA/AML and Sanctions Enforcement Standards for Foreign Correspondent Banking Relationships
On August 30, 2016, the U.S. Department of the Treasury, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of…
New York DFS Finalizes Stringent Anti-Money Laundering and Sanctions Regulation
- Jul 01, 2016
- Publications
New York DFS Finalizes Stringent Anti-Money Laundering and Sanctions Regulation
Following Maria Vullo's confirmation as Superintendent earlier this month, the New York Department of Financial Services ("DFS") yesterday finalized its closely watched proposed regulation on anti-money laundering (AML) monitoring and …
Client Alert: FinCEN Issues Sweeping New Requirements on Collection of Beneficial Ownership Information and Customer Due Diligence
- May 10, 2016
- Publications
Client Alert: FinCEN Issues Sweeping New Requirements on Collection of Beneficial Ownership Information and Customer Due Diligence
On May 6, 2016, the U.S. Treasury Department's Financial Crimes Enforcement Network ("FinCEN") released a final rule codifying new and existing customer due diligence ("CDD") requirements under the Bank Secrecy Act ("BSA") for covered …
Roberto Gonzalez and Jessica Carey Co-Author Article on AML Enforcement in The National Law Journal
- Feb 22, 2016
- Publications
Roberto Gonzalez and Jessica Carey Co-Author Article on AML Enforcement in The National Law Journal
Litigation partners Roberto Gonzalez and Jessica Carey co-authored an article in the February 22 issue of The National Law Journal.
FinCEN Imposes Anti-Money Laundering Reporting Requirements
- Feb 02, 2016
- Publications
FinCEN Imposes Anti-Money Laundering Reporting Requirements
The U.S. Treasury Department's Financial Crimes Enforcement Network (FinCEN) issued Geographic Targeting Orders ("GTO") imposing temporary reporting requirements on title insurers with respect to "all-cash" purchases of high-end…
Client Alert: Understanding the Changes to the Iran Sanctions Regime: OFAC Issues Guidance, General Licenses on JCPOA Implementation Day
- Jan 20, 2016
- Publications
Client Alert: Understanding the Changes to the Iran Sanctions Regime: OFAC Issues Guidance, General Licenses on JCPOA Implementation Day
On January 16, 2016, international inspectors verified that Iran had complied with the initial nuclear requirements of the Joint Comprehensive Plan of Action (the "JCPOA"), and the Secretary of State confirmed that verification.
FinCEN Proposes AML Regulations for Investment Advisers
- Sep 24, 2015
- Publications
FinCEN Proposes AML Regulations for Investment Advisers
The U.S. Department of the Treasury, Financial Crimes Enforcement Network ("FinCEN") proposed rules on August 25, 2015 that would broaden the application of the Bank Secrecy Act's ("BSA") suspicious activity reporting and anti-money…
Client Alert: Treasury Department’s Analysis of Existing AML and Anti-Terrorist Financing Regimes Recognizes Banks’ Efforts to Reduce the Flow of Illicit Funds Through the U.S. Financial System
- Jul 17, 2015
- Publications
Client Alert: Treasury Department’s Analysis of Existing AML and Anti-Terrorist Financing Regimes Recognizes Banks’ Efforts to Reduce the Flow of Illicit Funds Through the U.S. Financial System
The Treasury Department recently issued two companion reports, the National Money Laundering Risk Assessment and the National Terrorist Financing Risk Assessment, that address anti-money laundering and terrorist financing regulations…
Awards & Recognition
Paul, Weiss Partners Receive Law360 Distinguished Writing Award
- Feb 26, 2019
- Awards
Paul, Weiss Partners Receive Law360 Distinguished Writing Award
Firm chairman Brad Karp, corporate partner Mark Bergman and litigation partners Susanna Buergel, Roberto Gonzalez, Jane O’Brien and Elizabeth Sacksteder have been selected to receive the Law360 Distinguished Writing Award at the 2019…
Brad Karp Named “Attorney of the Year” by the New York Law Journal
- Oct 10, 2018
- Awards
Brad Karp Named “Attorney of the Year” by the New York Law Journal
Firm chair Brad Karp was named the 2018 New York Law Journal “Attorney of the Year.”
Brad Karp Named “Litigator of the Year” by The American Lawyer
- Dec 21, 2017
- Awards
Brad Karp Named “Litigator of the Year” by The American Lawyer
Firm chair Brad Karp was named a 2017 “Litigator of the Year” by The American Lawyer.
Jessica Carey and Roberto Gonzalez Receive Law360 Distinguished Writing Award
- Mar 28, 2017
- Awards
Jessica Carey and Roberto Gonzalez Receive Law360 Distinguished Writing Award
Litigation partners Jessica Carey and Roberto Gonzalez have been selected to receive the “Law360 Distinguished Writing Award” at the 2017 Burton Awards.
Paul, Weiss and Mark Mendelsohn Win Who’s Who Legal Awards for Investigations
- Apr 12, 2016
- Awards
Paul, Weiss and Mark Mendelsohn Win Who’s Who Legal Awards for Investigations
Paul, Weiss was named Investigations Law Firm of the Year and litigation partner Mark Mendelsohn was recognized as Investigations Lawyer of the Year at the 2016 Who's Who Legal Awards.
Jessica Carey and Salvatore Gogliormella Named Rising Stars by New York Law Journal
- Apr 06, 2016
- Awards
Jessica Carey and Salvatore Gogliormella Named Rising Stars by New York Law Journal
Litigation partner Jessica Carey and real estate partner Salvatore Gogliormella have been named New York Law Journal Rising Stars for 2016.
Sal Gogliormella and Roberto Gonzalez Named Rising Stars by Law360
- Mar 31, 2016
- Awards
Sal Gogliormella and Roberto Gonzalez Named Rising Stars by Law360
Real estate partner Salvatore Gogliormella and litigation partner Roberto Gonzalez have been named to Law360's Rising Stars for 2016 in the Real Estate and Banking categories, respectively.
Roberto Gonzalez Named to Hispanic Bar Association’s “Top Lawyers Under 40”
- Feb 04, 2016
- Awards
Roberto Gonzalez Named to Hispanic Bar Association’s “Top Lawyers Under 40”
Litigation partner Roberto Gonzalez has been named to the Hispanic National Bar Association's (HNBA) 2016 list of the twenty "Top Lawyers Under 40."