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. 

Our Practice

We have recently represented clients in some of the most significant matters in this space, including matters before the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and Financial Crimes Enforcement Network (FinCEN), the Department of Justice (DOJ), the Federal Reserve Board (FRB), the Office of the Comptroller of the Currency (OCC) and the New York Department of Financial Services (DFS).

Regulatory Insight. We have an unparalleled understanding of the legal and policy underpinnings of OFAC sanctions and BSA/AML regulations. Our team members have broad government experience drawn from the Department of the Treasury (including OFAC’s Enforcement Division), the Department of State, the DOJ and the White House. And we have gained particular experience representing non-U.S. banks and their U.S. branches before the DFS and the FRB. We have strong insight into the factors that motivate these agencies’ enforcement and other regulatory decisions. Our experience enables us to advise clients on how to stay ahead of emerging regulatory and enforcement trends. 

Regulatory Advice and Compliance Counseling. Our primary aim is to help clients avoid regulatory entanglements. We have advised numerous U.S. and non-U.S. clients on a broad range of economic sanctions and BSA/AML matters, including discrete issues regarding particular transactions, managing business interactions with parties that have been designated by OFAC or FinCEN and risk assessments concerning new products or business lines. Our team has recently assisted clients with navigating changes to the Iran, Russia-Ukraine, North Korea, Venezuela and Cuba sanctions programs and new regulations such as the DFS’s Part 504 rule, among other topics. We assist clients with reviewing Suspicious Activity Reports and responding to Section 314(a) requests. We also have experience updating compliance policies and procedures and implementing remedial measures. Our team has also had success in obtaining OFAC licenses in sensitive and novel matters.

Examinations, Investigations and Enforcement Defense. Clients come to us with their highest-stakes economic sanctions and BSA/AML matters. We are well known in particular for representing global financial institutions at all stages of engagement with the DFS, the FRB, OFAC, DOJ and other agencies. When faced with inquiries, examinations or subpoenas, we assist clients in understanding what matters to regulators and how to implement an effective response. We also have considerable experience conducting internal investigations across multiple jurisdictions designed to deter full-scale regulatory involvement and limit our clients’ exposure. And when necessary, we are particularly adept at helping clients navigate multi-agency enforcement probes, often obtaining civil and/or criminal resolutions that dramatically limit financial, business and reputational repercussions.

Transactional Due Diligence. We regularly counsel clients engaging in mergers and acquisitions, project finance and capital markets activities, and other significant transactions in order to assess potential economic sanctions and BSA/AML liability for past conduct and also aid in the mitigation of risks going forward. This includes conducting due diligence, drafting and negotiating contractual protections and implementing compliance and auditing protocols. 

Diverse, Global Practice. Our broad client base—which spans U.S. and non-U.S. companies in financial services, investment funds, energy, mining, manufacturing, professional services, trade and logistics, tourism, technology, telecommunications, and sports—ensures that we have dealt with a large number of sanctions and BSA/AML issues in a variety of permutations and contexts.

Our work also benefits from synergies with related practice areas including white collar and regulatory defense, export controls, anti-bribery/anti-corruption, CFIUS, anti-boycott regulation and defense industrial security matters.

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