Economic Sanctions & Anti-Money Laundering
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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.
Mark Mendelsohn Quoted in Regulatory Compliance Watch
February 11, 2022
Litigation partner Mark Mendelsohn was quoted extensively in “‘New era’ for compliance takes shape,” published in Regulatory Compliance Watch. The article discusses the rise in corruption and money laundering risk in the U.S. markets and regulators’ proposed measures to combat it, including potential SEC rulemaking on “enhanced disclosures” for private fund advisers. The Biden Administration has declared corruption and associated money laundering risk a threat to national security for the first time in American history, and private fund advisers should take note of Washington’s increased attention to compliance.
“What happens is, these various agencies all want to grow in terms of mandate and funding and head-count,” Mark says. “These agencies now have the opportunity because the White House is driving this process and agencies can say, ‘This is what we need, this is what we can accomplish, but we need support in this way.’”
Mark also discussed the ways in which smaller and mid-market funds in particular are likely to bear the most weight amid heightened regulatory scrutiny.
“A lot of smaller and mid-market funds have no idea what’s about to happen—and even when it happens, they still may not have any idea,” he says.
Private fund advisers may want to get ahead of any due diligence problems, Mark adds.
“Suppose Russia invades Ukraine,” he says, and the Biden Administration slaps sanctions on oligarchs. “What are you going to do if all of the sudden you’ve got an investor in your funds that you can’t do business with? There are all kinds of compliance issues. My sense is that many of the largely unregulated funds may be unprepared to deal with this.”