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.
Representative Engagements
- A U.S.-based global financial institution in a multi-year federal grand jury investigation of its compliance with BSA/AML requirements. The bank ultimately obtained a non-prosecution agreement, avoided appointment of an independent monitor, and paid a significantly reduced penalty.
- A global financial institution headquartered outside the U.S. in sanctions matters before the DFS, New York Federal Reserve and other regulators.
- A global financial institution headquartered outside the U.S. in BSA/AML matters, including advising on pro-active remedial measures and global compliance program enhancements.
- Multiple China-based global financial institutions in various BSA/AML and sanctions matters, including DFS and New York Federal Reserve investigations and enforcement actions, response to OFAC subpoenas and ongoing training and compliance advice.
- A U.S.-based financial institution in connection with economic sanctions, BSA /AML and other global compliance issues.
- Multiple non-U.S. industrial companies and their U.S. subsidiaries in sanctions and export controls matters.
- A major U.S.-based cruise line in connection with OFAC and other U.S. regulatory issues, including initiating travel to Cuba by cruise ships.
- The audit committee of a technology company in an internal investigation and voluntary disclosure to OFAC.
- An international music publisher in connection with OFAC-related matters involving Cuba.
- A natural resources company in an internal investigation regarding sanctions and bribery allegations.
- A U.S. company with global operations in disclosures of potential sanctions issues to OFAC.
- Multiple private equity firms and other companies in connection with sanctions and BSA/AML diligence for acquisitions and investments, as well as strategic regulatory advice relating to market entry.