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.
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Events & Publications
Economic Sanctions and Anti-Money Laundering Developments: 2020 Year in Review
- Feb 22, 2021
- Publications
Economic Sanctions and Anti-Money Laundering Developments: 2020 Year in Review
In this annual review, we survey U.S. economic sanctions and anti-money laundering regulatory and enforcement developments in 2020 and provide an outlook for the year ahead under the new administration. This year’s memo includes…
Commerce Publishes Information and Communications Technology and Services (ICTS) Interim Rule in the Final Days of the Trump Administration
- Jan 27, 2021
- Publications
Commerce Publishes Information and Communications Technology and Services (ICTS) Interim Rule in the Final Days of the Trump Administration
The Department of Commerce recently issued an interim final rule to implement President Trump’s Information and Communications Technology and Services (“ICTS”) Executive Order of May 2019. The order was aimed at threats posed by the…
FCPA Enforcement and Anti-Corruption Developments: 2020 Year In Review
- Jan 22, 2021
- Publications
FCPA Enforcement and Anti-Corruption Developments: 2020 Year In Review
Despite the significant obstacles presented by COVID-19, the DOJ and the SEC assessed a record-breaking total in corporate FCPA penalties, and foreign authorities assessed a similar amount. The number of corporate FCPA enforcement…
Update on Communist Chinese Military Companies (CCMCs) Sanctions: Amended Executive Order, New OFAC Guidance, Expanded Criteria for CCMCs, and Additional CCMCs Identified
- Jan 16, 2021
- Publications
Update on Communist Chinese Military Companies (CCMCs) Sanctions: Amended Executive Order, New OFAC Guidance, Expanded Criteria for CCMCs, and Additional CCMCs Identified
President Trump’s executive order prohibiting U.S. persons from engaging in transactions involving publicly traded securities of any identified “Communist Chinese military company” (CCMC) recently went into effect. This alert covers…
Jessica Carey, Roberto Gonzalez and Joshua Thompson Publish Expert Analysis in Law360 on the NDAA’s Overhaul of AML Policy in the U.S.
- Jan 07, 2021
- Publications
Jessica Carey, Roberto Gonzalez and Joshua Thompson Publish Expert Analysis in Law360 on the NDAA’s Overhaul of AML Policy in the U.S.
Litigation partners Jessica Carey and Roberto Gonzalez and corporate associate Joshua Thompson published an article in Law360, “How Defense Bill Will Overhaul AML Policy In U.S.,” on January 7.
New Guidance Clarifies OFAC’s Broad Interpretation of Recent Sanctions Against Communist Chinese Military Companies
- Jan 04, 2021
- Publications
New Guidance Clarifies OFAC’s Broad Interpretation of Recent Sanctions Against Communist Chinese Military Companies
OFAC recently published guidance clarifying the scope of the Trump Administration’s sanctions prohibiting U.S. persons from engaging in transactions involving publicly traded securities of any identified “Communist Chinese military…
FinCEN Proposes New Requirements for Reporting and Recordkeeping on Certain Transactions Involving Convertible Virtual Currency and Digital Asset Transactions
- Dec 29, 2020
- Publications
FinCEN Proposes New Requirements for Reporting and Recordkeeping on Certain Transactions Involving Convertible Virtual Currency and Digital Asset Transactions
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) recently proposed rulemaking that would extend existing Bank Secrecy Act reporting and recordkeeping requirements on financial institutions for certain…
United States Imposes Sanctions on Turkey under CAATSA Section 231 for Purchase of Russian Missile System
- Dec 21, 2020
- Publications
United States Imposes Sanctions on Turkey under CAATSA Section 231 for Purchase of Russian Missile System
The United States recently imposed sanctions on Turkey’s Presidency of Defense Industries under the Countering America’s Adversaries Through Sanctions Act (CAATSA), which mandates sanctions against non-U.S. persons who conduct…
Congress to Include Significant Expansion of Beneficial Ownership Disclosure Requirements for U.S. Companies and non-U.S. Companies Registered to do Business in the United States as a Part of the 2021 NDAA
- Dec 08, 2020
- Publications
Congress to Include Significant Expansion of Beneficial Ownership Disclosure Requirements for U.S. Companies and non-U.S. Companies Registered to do Business in the United States as a Part of the 2021 NDAA
As part of the fiscal year 2021 National Defense Authorization Act (2021 NDAA), which is expected to be passed in the coming weeks, Congress has included a significant expansion of beneficial ownership disclosure requirements for U.S. …
Paul, Weiss Presents Webinar on Biden Administration Policy and Regulatory Agenda
- Nov 17, 2020
- Events
Paul, Weiss Presents Webinar on Biden Administration Policy and Regulatory Agenda
On November 17, Paul, Weiss hosted a webinar, “Transition to a Biden Administration: Strategies and Insights,” that offered insights into the likely policy, legislative and regulatory priorities of the new administration.
President Trump Issues an Executive Order Prohibiting U.S. Persons from Investing in Listed “Communist Chinese Military Companies”
- Nov 18, 2020
- Publications
President Trump Issues an Executive Order Prohibiting U.S. Persons from Investing in Listed “Communist Chinese Military Companies”
President Trump recently issued new sanctions prohibiting U.S. persons from engaging in transactions involving securities of any identified “Communist Chinese military company” (CCMC) as of January 11, 2021, subject to a one year…
FCPA Developments: Q3 2020
- Oct 16, 2020
- Publications
FCPA Developments: Q3 2020
Despite COVID-related challenges, FCPA enforcement by the DOJ and the SEC continued at full speed in the third quarter of 2020. Enforcement activity included three corporate resolutions by the DOJ and four resolutions by the SEC, as…
Roberto Gonzalez and Rachel Fiorill Author USA Chapter in ICLG’s Sanctions 2021 Guide
- Oct 06, 2020
- Publications
Roberto Gonzalez and Rachel Fiorill Author USA Chapter in ICLG’s Sanctions 2021 Guide
Litigation partner Roberto Gonzalez and counsel Rachel Fiorill served as contributing editors and authored two chapters in the International Comparative Legal Guide (ICLG): Sanctions 2021, published by the Global Legal Group Ltd.,…
The OCC Issues Guidance Confirming that National Banks and Federal Savings Associations May Hold Reserves for Certain Stablecoins
- Sep 29, 2020
- Publications
The OCC Issues Guidance Confirming that National Banks and Federal Savings Associations May Hold Reserves for Certain Stablecoins
U.S. banks and federal savings associations may accept deposits that serve as reserves for stablecoin backed on a 1:1 basis by a single fiat currency in a hosted wallet.
Second Circuit Rejects Evasion-of-Secondary-Sanctions Theory; Upholds DOJ’s Use of Bank Fraud Statute in Sanctions Prosecution
- Aug 31, 2020
- Publications
Second Circuit Rejects Evasion-of-Secondary-Sanctions Theory; Upholds DOJ’s Use of Bank Fraud Statute in Sanctions Prosecution
In a decision that offers greater clarity on what conduct is, and is not, subject to criminal prosecution with regards to sanctions-related violations, the Second Circuit recently upheld the conviction of a former executive of…
Federal Agencies Provide Guidance on BSA/AML Enforcement and Due Diligence Requirements
- Aug 24, 2020
- Publications
Federal Agencies Provide Guidance on BSA/AML Enforcement and Due Diligence Requirements
Federal banking agencies, along with FinCEN, recently issued new guidance on BSA/AML enforcement and customer due diligence obligations.
Litigation Team Co-Author Article on New Sanctions Risks for Non-U.S. Companies
- Aug 05, 2020
- Publications
Litigation Team Co-Author Article on New Sanctions Risks for Non-U.S. Companies
Litigation partner Roberto Gonzalez, counsel Rachel Fiorill and associate Anand Sithian co-authored an article, "Essentra Case Signals New Sanctions Risks For Non-US Cos.," that appeared in the Expert Analysis section of Law360.
DOJ and OFAC Enforcement Actions Against Essentra FZE Signal New Sanctions Risks for Non-U.S. Companies Utilizing the U.S. Financial System
- Jul 23, 2020
- Publications
DOJ and OFAC Enforcement Actions Against Essentra FZE Signal New Sanctions Risks for Non-U.S. Companies Utilizing the U.S. Financial System
DOJ and OFAC recently announced parallel sanctions resolutions with Essentra FZE Company Limited, a UAE-based supplier of cigarette products. Essentra FZE received payments in U.S. dollars and UAE Dirham into bank accounts held at a…
President Trump Signs the Hong Kong Autonomy Act into Law and Issues an Implementing Executive Order
- Jul 21, 2020
- Publications
President Trump Signs the Hong Kong Autonomy Act into Law and Issues an Implementing Executive Order
President Trump recently signed the Hong Kong Autonomy Act (HKAA) into law and issued an executive order implementing the HKAA.
UK FCA Imposes £37 Million Penalty on Commerzbank for AML Failures
- Jun 22, 2020
- Publications
UK FCA Imposes £37 Million Penalty on Commerzbank for AML Failures
The UK Financial Conduct Authority recently ordered Commerzbank to pay more than £37 million penalty for years of anti-money laundering failures in systems and controls.
DOJ 2020 Guidance for Evaluating Corporate Compliance Incorporates Feedback From Business and Compliance Communities
- Jun 08, 2020
- Publications
DOJ 2020 Guidance for Evaluating Corporate Compliance Incorporates Feedback From Business and Compliance Communities
The DOJ’s Criminal Division released updated guidance regarding the manner in which prosecutors evaluate the effectiveness of corporate compliance programs. The guidance makes clear that companies should continuously update their…
Roberto Gonzalez Moderates Institute of International Bankers’ Sanctions Panel
- Jun 01, 2020
- Events
Roberto Gonzalez Moderates Institute of International Bankers’ Sanctions Panel
Litigation partner Roberto Gonzalez moderated a panel, “Sanctions and Security: What’s New at OFAC in 2020,” as part of the Institute of International Bankers’ two-day virtual seminar.
U.S. Government Issues Updated Sanctions Compliance Guidance for the Maritime Industry
- May 19, 2020
- Publications
U.S. Government Issues Updated Sanctions Compliance Guidance for the Maritime Industry
On May 14, 2020, the U.S. Department of State, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and the U.S. Coast Guard (collectively, the “Agencies”) issued updated guidance entitled, “Guidance to…
OFAC Enforcement Action against BIOMIN America, Inc. Highlights the Consequences of Failing to Seek and Implement Appropriate Compliance Advice
- May 14, 2020
- Publications
OFAC Enforcement Action against BIOMIN America, Inc. Highlights the Consequences of Failing to Seek and Implement Appropriate Compliance Advice
On May 6, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced a $257,862 settlement agreement with BIOMIN America, Inc. (“BIOMIN America”), an animal nutrition company based in Overland Park,…
Bank Hapoalim Enters into Criminal and Civil Resolutions for Its Participation in Separate Tax Evasion and Money Laundering Conspiracies, and Agrees to Pay Nearly $1 Billion in Penalties
- May 05, 2020
- Publications
Bank Hapoalim Enters into Criminal and Civil Resolutions for Its Participation in Separate Tax Evasion and Money Laundering Conspiracies, and Agrees to Pay Nearly $1 Billion in Penalties
The DOJ, Federal Reserve and the New York State Department of Financial Services announced nearly $875 million in penalties against Bank Hapoalim and its Swiss subsidiary.
NY DFS Files Enforcement Action against Opioid Manufacturer for Insurance Fraud
- May 01, 2020
- Publications
NY DFS Files Enforcement Action against Opioid Manufacturer for Insurance Fraud
On April 16, 2020, the New York Department of Financial Services (“DFS”) issued a Statement of Charges and Notice of Hearing against Irish pharmaceutical company Mallinckrodt plc and several of its U.S. subsidiaries (collectively,…
Industrial Bank of Korea Reaches $86 Million AML Resolution with DOJ, NY Attorney General, and NY DFS
- Apr 24, 2020
- Publications
Industrial Bank of Korea Reaches $86 Million AML Resolution with DOJ, NY Attorney General, and NY DFS
The DOJ, the N.Y. Attorney General and the N.Y. Department of Financial Services (DFS) recently announced an $86 million resolution with Industrial Bank of Korea (IBK) in connection with criminal violations of the Bank Secrecy Act and …
New York DFS Issues Emergency Regulation on Mortgage Forbearance and Certain Fees in Response to COVID-19 Pandemic
- Mar 25, 2020
- Publications
New York DFS Issues Emergency Regulation on Mortgage Forbearance and Certain Fees in Response to COVID-19 Pandemic
Under an emergency regulation issued by the NY Department of Financial Services, DFS-regulated banking organizations and mortgage servicers must grant a 90-day forbearance on residential mortgage payments for New York residents who…
Gov. Cuomo Requires New York-Regulated Banks to Grant Forbearances in Light of the COVID-19 Pandemic and Issues Related Directives to NY DFS
- Mar 23, 2020
- Publications
Gov. Cuomo Requires New York-Regulated Banks to Grant Forbearances in Light of the COVID-19 Pandemic and Issues Related Directives to NY DFS
N.Y. Gov. Andrew Cuomo has issued an executive order temporarily deeming the failure of a New York-regulated bank to grant a forbearance to an individual or business in certain circumstances an “unsafe and unsound” business practice.
New York DFS Grants Temporary Relief and Requires Regulated Entities to Submit Descriptions of COVID-19 Preparedness Plans
- Mar 19, 2020
- Publications
New York DFS Grants Temporary Relief and Requires Regulated Entities to Submit Descriptions of COVID-19 Preparedness Plans
The N.Y. Department of Financial Services (DFS) has taken a number of recent steps in response to the COVID-19 pandemic, including granting temporary regulatory relief and filing extensions to regulated entities, and requiring such…
OFAC Cites the Use of U.S.-Origin Software and U.S. Network Infrastructure in Reaching a Nearly $8 Million Settlement with a Swiss Commercial Aviation Services Company
- Mar 16, 2020
- Publications
OFAC Cites the Use of U.S.-Origin Software and U.S. Network Infrastructure in Reaching a Nearly $8 Million Settlement with a Swiss Commercial Aviation Services Company
The U.S. Treasury Department’s Office of Foreign Assets Control has announced a $7,829,640 settlement agreement with Geneva-based Société Internationale de Télécommunications Aéronautiques.
2020 FCPA Developments: A Judge Overturns Hoskins’s FCPA Guilty Verdict Under an Agency Theory; Cardinal Health Resolves FCPA Investigation with the SEC
- Mar 13, 2020
- Publications
2020 FCPA Developments: A Judge Overturns Hoskins’s FCPA Guilty Verdict Under an Agency Theory; Cardinal Health Resolves FCPA Investigation with the SEC
On February 26, 2020, the U.S. District Court for the District of Connecticut entered a judgment of acquittal for Lawrence Hoskins on all Foreign Corrupt Practices Act (“FCPA”) charges.[1] The ruling partly overturns a jury’s verdict…
FinCEN Imposes Its First Penalty on a Bank Compliance Officer for $450,000 for Failing to Prevent AML Violations
- Mar 09, 2020
- Publications
FinCEN Imposes Its First Penalty on a Bank Compliance Officer for $450,000 for Failing to Prevent AML Violations
On March 4, 2020, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a consent order assessing a $450,000 civil money penalty against Michael LaFontaine, a former Chief Operational Risk Officer at U.S.…
Wells Fargo Reaches Resolutions with DOJ and SEC for $3 Billion, Agrees to a Deferred Prosecution Agreement
- Feb 24, 2020
- Publications
Wells Fargo Reaches Resolutions with DOJ and SEC for $3 Billion, Agrees to a Deferred Prosecution Agreement
On February 21, 2020, Wells Fargo & Company and its subsidiary, Wells Fargo Bank, N.A. (collectively, “Wells Fargo”), entered into resolutions with the Department of Justice (“DOJ”) and the Securities and Exchange Commission (the…
Economic Sanctions and Anti-Money Laundering Developments: 2019 Year in Review
- Jan 31, 2020
- Publications
Economic Sanctions and Anti-Money Laundering Developments: 2019 Year in Review
This memorandum surveys economic sanctions and anti-money laundering (“AML”) developments and trends in 2019 and provides an outlook for the year ahead.
OCC Takes Unprecedented Enforcement Actions Against Eight Former Wells Fargo Executives
- Jan 28, 2020
- Publications
OCC Takes Unprecedented Enforcement Actions Against Eight Former Wells Fargo Executives
As the latest chapter in the aftermath of the Wells Fargo fake accounts scandal, the OCC announced enforcement actions against eight former Wells Fargo executives for their roles in the bank’s “systemic sales practices misconduct.”
FCPA Enforcement and Anti-Corruption Developments - 2019 Year in Review
- Jan 24, 2020
- Publications
FCPA Enforcement and Anti-Corruption Developments - 2019 Year in Review
In this annual review, we reflect on the most significant anti-corruption and FCPA enforcement and policy trends of 2019 and share our insights on developing U.S. and global anti-corruption efforts in 2020.
DOJ Announces Revised Export Control and Sanctions Enforcement Policy for Companies, Including Financial Institutions
- Dec 19, 2019
- Publications
DOJ Announces Revised Export Control and Sanctions Enforcement Policy for Companies, Including Financial Institutions
The U.S. Department of Justice’s National Security Division recently announced a revised policy designed to encourage companies, including financial institutions, to make voluntary self-disclosures to the DOJ in connection with…
OFAC Enforcement Action against U.S. Aviation Company Shows the Importance of Ongoing Monitoring over the Course of a Contractual Relationship
- Dec 09, 2019
- Publications
OFAC Enforcement Action against U.S. Aviation Company Shows the Importance of Ongoing Monitoring over the Course of a Contractual Relationship
In a recent settlement agreement, OFAC faulted a U.S. aviation company for failing to monitor or otherwise verify the actual location of leased aircraft engines over the life of the leases.
Roberto Gonzalez to Speak at ACI’s NY Forum on Economic Sanctions
- Dec 10, 2019
- Events
Roberto Gonzalez to Speak at ACI’s NY Forum on Economic Sanctions
Litigation partner Roberto Gonzalez, the co-chair of Paul, Weiss’s Economic Sanctions and AML practice group, will speak on a panel at the American Conference Institute’s 10th NY Forum on Economic Sanctions.
Jury Convicts Foreign National of FCPA Violations under Agency Theory
- Nov 21, 2019
- Publications
Jury Convicts Foreign National of FCPA Violations under Agency Theory
On November 8, 2019, a Connecticut jury found Lawrence Hoskins, a British national and former executive of the French power and rail transportation company, Alstom S.A., guilty of participating in a scheme to bribe Indonesian…
Roberto Gonzalez and Rachel Fiorill Author USA Chapter for ICLG’s Inaugural Comparative Guide to Sanctions
- Oct 21, 2019
- Publications
Roberto Gonzalez and Rachel Fiorill Author USA Chapter for ICLG’s Inaugural Comparative Guide to Sanctions
Litigation partner Roberto Gonzalez and counsel Rachel Fiorill served as contributing editors and authored two chapters for the inaugural edition of The International Comparative Legal Guide (ICLG) to: Sanctions 2020, published by the …
Federal Agencies Issue Joint Statement on AML/CFT Obligations, and IRS Updates Guidance, for Digital Assets
- Oct 15, 2019
- Publications
Federal Agencies Issue Joint Statement on AML/CFT Obligations, and IRS Updates Guidance, for Digital Assets
The CFTC, the SEC and FinCen recently issued a joint statement reminding those engaged in activities involving digital assets of their anti-money laundering and counter-terrorist funding obligations under the Bank Secrecy Act
Roberto Gonzalez to Speak on Economic Sanctions at Hispanic National Bar Association Convention in New York
- Sep 26, 2019
- Events
Roberto Gonzalez to Speak on Economic Sanctions at Hispanic National Bar Association Convention in New York
Litigation partner Roberto Gonzalez will speak on a panel at the Hispanic National Bar Association’s 2019 convention in New York.
OFAC Reaches Settlement Agreement with U.K. Bank for Complex Payment Structures Used to Circumvent U.S. Sanctions
- Sep 19, 2019
- Publications
OFAC Reaches Settlement Agreement with U.K. Bank for Complex Payment Structures Used to Circumvent U.S. Sanctions
On September 17, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $4,000,000 settlement agreement with the British Arab Commercial Bank plc (“BACB”), a commercial bank located in the…
FinCEN Announces Launch of New Global Investigations Division Focused on Exercising Section 311 and Geographic Targeting Order Authorities
- Aug 30, 2019
- Publications
FinCEN Announces Launch of New Global Investigations Division Focused on Exercising Section 311 and Geographic Targeting Order Authorities
On August 28, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced the launch of a new Global Investigations Division (“GID”), which will be responsible for implementing “targeted investigation…
Does President Trump Have Authority to Force U.S. Companies to Leave China?
- Aug 26, 2019
- Publications
Does President Trump Have Authority to Force U.S. Companies to Leave China?
On August 23, 2019, President Trump tweeted that “American companies are hereby ordered to immediately start looking for an alternative to China, including bringing. . .your companies [home] and making products in the USA.” In further …
D.C. Circuit Upholds Decision Requiring Three Chinese Banks to Produce Documents Located in China to the U.S. Government
- Aug 12, 2019
- Publications
D.C. Circuit Upholds Decision Requiring Three Chinese Banks to Produce Documents Located in China to the U.S. Government
On July 30, 2019, the U.S. Court of Appeals for the District of Columbia affirmed civil contempt orders by the D.C. District Court against three Chinese banks for their failure to produce documents in response to U.S. government…
FCPA Enforcement and Anti-Corruption Developments: 2019 Mid-Year Review
- Jul 18, 2019
- Publications
FCPA Enforcement and Anti-Corruption Developments: 2019 Mid-Year Review
Robust FCPA enforcement activity continued in the first half of 2019. The DOJ and the SEC—resolving four and five corporate enforcement actions, respectively—assessed a combined total of $1.5 billion in corporate penalties, of which…
Paul, Weiss Co-Hosts Panel Discussion With China General Chamber of Commerce USA
- Jun 25, 2019
- Events
Paul, Weiss Co-Hosts Panel Discussion With China General Chamber of Commerce USA
On June 25, Paul, Weiss co-hosted an event with the China General Chamber of Commerce USA (CGCC), “Detecting and Reporting Suspicious Transactions and Preventing Sanctions Violations.”
New York DFS Creates New Cybersecurity Division
- May 29, 2019
- Publications
New York DFS Creates New Cybersecurity Division
On May 22, 2019, the New York State Department of Financial Services (“DFS”) announced the creation of a new Cybersecurity Division, which it described as the “first of its kind at a banking or insurance regulator.”
OFAC Issues Guidance on Sanctions Compliance Programs and Flags “Root Causes” Underlying Prior Enforcement Actions
- May 14, 2019
- Publications
OFAC Issues Guidance on Sanctions Compliance Programs and Flags “Root Causes” Underlying Prior Enforcement Actions
On May 2, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued guidance entitled “A Framework for OFAC Compliance Commitments” (the “Framework”), that strongly encourages companies to “develop,…
Justin Lerer Speaks on Anti-Money Laundering Enforcement
- May 01, 2019
- Events
Justin Lerer Speaks on Anti-Money Laundering Enforcement
Litigation counsel Justin Lerer participated in a panel discussion on the “Shifting Tides in Anti-Money Laundering Enforcement and Regulation.”
New York DFS Creates New “Powerhouse” Division Combining the Enforcement Division and Financial Frauds and Consumer Protection Division
- May 03, 2019
- Publications
New York DFS Creates New “Powerhouse” Division Combining the Enforcement Division and Financial Frauds and Consumer Protection Division
On April 29, 2019, Linda Lacewell, the Acting Superintendent of the New York State Department of Financial Services (“DFS”), announced the combination of DFS’s previously separate Enforcement Division and Financial Frauds and Consumer …
UniCredit Group Banks Agree to Pay a Combined $1.3 Billion Penalty for Iranian and Other Sanctions Violations; One Bank Pleads Guilty
- May 01, 2019
- 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…
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
Richard Elliott Named Among the 25 Most Respected Sanctions Lawyers in D.C.
- Nov 07, 2019
- Awards
Richard Elliott Named Among the 25 Most Respected Sanctions Lawyers in D.C.
International trade counsel Richard Elliott was featured in the Global Investigations Review’s most recent issue, which lists him among the 25 most respected sanctions lawyers in Washington, D.C.
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."