Rapidly changing national security and foreign policy priorities create major risks for both U.S. and foreign companies and financial institutions engaged in international business. Even routine business transactions can pose economic sanctions risks, while violations carry increasingly onerous penalties and the risk of serious reputational damage. Complicating compliance, sanctions regulation is often highly discretionary and lacking in clear guidance. Our dynamic and highly experienced team can help you navigate the nuances of this complex regulatory environment to manage the risks through pragmatic and cost-effective solutions.
Our full-service sanctions practice proactively helps clients manage risks by developing compliance programs and procedures that are tailored to both needs and resources. We routinely counsel clients on specific transactions and issues and, to meet their business needs, engage with OFAC to obtain licenses or interpretive guidance. Additionally, our team has vast experience navigating and resolving enforcement investigations and proceedings; it includes OFAC’s former assistant director of enforcement, which enables us to offer our clients unmatched governmental insight and perspective. We have vigorously defended against and resolved numerous enforcement matters, including complex multiagency, multijurisdictional proceedings brought jointly by OFAC, the Department of Justice, New York State regulators, and other agencies that included internal reviews and “look backs.” When necessary, we leverage the experience of our firm’s highly regarded white collar practice.
Our more than 30 years of sanctions experience derives from every area and industry, allowing us to give your business a big-picture perspective. Our diverse clients include some of the largest financial institutions and payments companies in the world, as well as domestic and foreign industry leaders in transportation, shipping, pharmaceuticals, telecommunications, energy, manufacturing, and defense.