Economic Sanctions

We engage with clients at the ground level to help them detect and prevent potential violations of law through our day-to-day sanctions compliance counseling. Our team regularly assists clients, including the world’s largest financial institutions and corporations, in reviewing, developing and implementing global economic sanctions compliance programs to identify and prevent potential legal breaches. We design and tailor compliance programs to meet each client’s risk profile and business requirements, taking into account the institution’s existing organizational and management structures and cultural and global needs, as well as the expectations of regulators.

We have substantial experience helping our clients prepare for and respond to regulatory inquiries and examinations, assessing the need for and drafting voluntary disclosures and license requests, and conducting internal investigations and transactional due diligence. Our attorneys regularly work with every major sanctions authority, including the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of State, the U.K.’s Office of Financial Sanctions Implementation (OFSI) and key European member state competent authorities, including Direction Générale du Trésor (DGT) in France and Bundesamt für Wirtschaft und Ausfuhrkontrolle (BAFA) in Germany. We also have extensive experience working with every major federal and state financial services regulator in the U.S., as well as the financial services regulators in the U.K. and many European jurisdictions.

Our sanctions transactional review and support services are an extension of our position as a leader in global M&A. The combination of our compliance and enforcement counseling experience and our global deal platform positions us to draw on the necessary resources to work with clients to identify and manage “deal-stopping” issues at an early stage — or before entering into a transaction — and to monitor these matters through the life of a transaction. Conducting proper transaction reviews, including advising on the risks associated with complex transactions, completing comprehensive pre- and post-transaction due diligence, and drafting and negotiating relevant contractual terms, are key tools to ensure compliance with sanctions laws and regulations, and mitigate the risk of enforcement actions or reputational damage.

We vigorously defend our clients in enforcement proceedings brought by regulatory agencies and prosecutors, including OFAC, the Department of Justice (DOJ), the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation and the New York State Department of Financial Services. We have successfully resolved numerous cross-border and multi-agency civil and criminal investigations.

Our attorneys also advise clients in a wide variety of matters involving the U.K. Office of Financial Sanctions Implementation, the U.K. Serious Fraud Office, the U.K. Financial Conduct Authority, the U.K. Prudential Regulatory Authority, the German Federal Financial Supervisory Authority and public prosecutors, the French National Financial Prosecutor’s Office (Parquet National Financier) and the French Ministry of Finance, among others.

We also have substantial experience with post-enforcement remediation matters and monitorships, including advising on the design of remedial measures, including modifications to sanctions compliance frameworks and in-house training programs. We advise our clients on executing sanctions lookbacks mandated by regulators, and provide legal and strategic advice to clients who engage monitors and independent consultants regarding the conduct of such reviews and in responding to findings and recommendations.

Many of our attorneys have government experience directly related to economic sanctions and related areas — such as export controls, anti-money laundering and international trade — including at OFAC, the U.S. Department of State, the DOJ, FinCEN, the White House, the National Security Council, the Office of the U.S. Trade Representative, the U.S. Department of the Treasury’s Office of the General Counsel and Office of Terrorist Financing and Financial Crimes, the Office of the Comptroller of the Currency, and the Board of Governors of the Federal Reserve System.

The practice and its attorneys also have been recognized by Chambers, U.S. News — Best Lawyers Best Law Firms, Lawdragon, Who’s Who Legal, IFLR1000 and the Women in Business Law European Awards. Our attorneys have served on the State Department’s Advisory Committee on International Economic Policy: Sanctions Subcommittee and Advisory Committee on Public International Law, and the American Bar Association Standing Committee on Law and National Security.