Economic
Sanctions &
Anti-Money
Laundering
Our team provides expert guidance to both U.S. and international clients across various industries on complex U.S. economic sanctions and Bank Secrecy Act/anti-money laundering (BSA/AML) issues. Leveraging our extensive regulatory defense and white-collar experience, we assist clients in responding to regulatory inquiries, examinations, and subpoenas, conducting internal investigations, and managing multi-agency civil and criminal investigations. Our services also include regulatory advice, compliance counseling, and transactional due diligence.
We have represented clients in high-profile matters before key regulatory bodies such as 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
Our team possesses a deep understanding of the legal and policy foundations of OFAC sanctions and BSA/AML regulations, enriched by our members' extensive government experience from the Department of the Treasury, the Department of State, the DOJ, and the White House. We have particular expertise in representing non-U.S. banks and their U.S. branches before the DFS and the FRB, providing us with valuable insights into the motivations behind these agencies' enforcement and regulatory decisions. This experience allows us to help clients anticipate and navigate emerging regulatory and enforcement trends.
Regulatory Advice and Compliance Counseling
Our primary goal is to help clients avoid regulatory issues. We have advised numerous clients on a wide range of economic sanctions and BSA/AML matters, including specific transaction issues, managing interactions with OFAC or FinCEN-designated parties, and conducting risk assessments for new products or business lines. Recently, we have assisted clients with navigating changes to sanctions programs involving Iran, Russia-Ukraine, North Korea, Venezuela, and Cuba, as well as new regulations like the DFS's Part 504 rule. We also help clients review Suspicious Activity Reports, respond to Section 314(a) requests, update compliance policies, and implement remedial measures. Our team has successfully obtained OFAC licenses in sensitive and novel cases.
Examinations, Investigations and Enforcement Defense
We are renowned for representing global financial institutions in high-stakes economic sanctions and BSA/AML matters. We assist clients in understanding regulatory priorities and crafting effective responses to inquiries, examinations, or subpoenas. Our team conducts internal investigations across multiple jurisdictions to prevent extensive regulatory involvement and minimize client exposure. When necessary, we adeptly navigate multi-agency enforcement probes, often securing resolutions that significantly reduce financial, business, and reputational impacts.
Transactional Due Diligence
We regularly advise clients on mergers and acquisitions, project finance, capital markets activities, and other significant transactions to assess and mitigate potential economic sanctions and BSA/AML liabilities. This includes conducting due diligence, drafting and negotiating contractual protections, and implementing compliance and auditing protocols.
Diverse, Global Practice
Our diverse client base spans various sectors, including financial services, investment funds, energy, mining, manufacturing, professional services, trade and logistics, tourism, technology, telecommunications, and sports. This broad experience ensures we have encountered a wide array of sanctions and BSA/AML issues in different contexts. Our work is further enhanced by synergies with related practice areas such as white-collar and regulatory defense, export controls, anti-bribery/anti-corruption, CFIUS, anti-boycott regulation, and defense industrial security matters.
Recent Engagements
- A top-five global bank in an investigation by the Manhattan U.S. Attorney’s Office related to U.S. dollar-clearing activity and related anti-money laundering (AML) controls and in a prior investigation by the Federal Reserve and the NY DFS regarding alleged sanctions violations.
- Shinhan Bank America in the successful resolution of BSA/AML inquiries by the NY DFS the FDIC, and FinCEN.
- Citigroup in a multi-year federal grand jury investigation of its compliance with BSA/AML requirements that resulted in a non-prosecution agreement and a significantly reduced penalty.
- Industrial and Commercial Bank of China (ICBC) and its New York branch in the successful resolution of BSA/AML and CSI-related inquiries by the New York State Department of Financial Services and the Federal Reserve.
- The National Bank of Pakistan and its New York branch in a successful resolution of BSA./AML and sanctions inquiries by the New York Department of Financial Services and Federal Reserve.
- Standard Chartered Bank in resolving a six-year sanctions investigations into its historic violations and control deficiencies by six U.S. federal and state agencies and the UK’s Financial Conduct Authority (FCA).
- A U.S. fintech company in DOJ and other agency investigations regarding alleged BSA/AML and sanctions violations.
- Several Asia-based technology companies in responding to investigations by the Commerce Department under the information and communications technology and services (ICTS) executive order.
- A major U.S.-based manufacturer in the internal investigation of whistleblower allegations regarding alleged Iran sanctions violations, and a subsequent voluntary self-disclosure to OFAC that resulted in a no-action letter.
- A U.S. based movie studio in regulatory advice and counterparty diligence regarding Russian sanctions.
- An Asia-based manufacturer in connection with the resolution of a DOJ investigation into potential sanctions and bank fraud violations regarding alleged business dealings with North Korea.
- Multiple Chinese banks in connection with BSA/AML and sanctions investigations and regulatory advice, training and compliance counseling.
- Multiple U.S. and non-U.S. clients in interactions with OFAC regarding licensing applications, requests for interpretive advice, de-listing requests, and the filing of voluntary disclosures and subpoena responses.
- A major non-U.S. technology company in engaging with multiple U.S. government agencies regarding privacy, data security, and national security concerns regarding a mobile app.
- 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.
