Economic Sanctions

Overview

Our team provides experienced advice and representation on economic sanctions matters before the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the U.S. Department of State, and state authorities. We have extensive experience across all OFAC sanctions programs, including sanctions relating to Russia, Iran, Venezuela, Cuba, and China, as well as OFAC’s activity-based sanction programs, such as Magnitsky and non-proliferation sanctions.

We provide the following services for clients on sanctions matters:

  • Advise on sanctions compliance in connection with international transactions
  • Conduct sanctions-related due diligence on mergers and acquisitions
  • Handle OFAC licensing matters
  • Develop and review compliance programs
  • Represent parties in connection with subpoenas, investigations, and enforcement proceedings
  • Prepare and submit voluntary disclosures to OFAC
  • Compliance audits
  • Development of compliance programs
  • Advise non-U.S. clients on the secondary sanctions implications of U.S. sanctions programs
  • Provide sanctions compliance training

Represent parties in connection with petitions to be removed from sanctions lists

Experience

  • Represented the U.S. affiliate of an international logistics and freight forwarding in connection with a multi-jurisdictional investigation of an air cargo flight for sanctions violations.
  • Assisted a global industrial conglomerate with developing and maintaining a globally compliant sanctions risk management program.
  • Advised a global freight forwarding and logistics company on day-to-day trade compliance matters, including multijurisdictional sanctions issues and updating the company’s procedures and operations in response to a complex and far-reaching customs ruling.
  • Advised a UK software company serving the airline industry in various respects, including managing flight books and inter-airline settlement of payments, with regard to its compliance with sanctions laws.
  • Represented a state-owned foreign bank in a sanctions and BSA/AML investigation by the DOJ and the OFAC.
  • Represented an international tobacco company in connection with an investigation by the DOJ National Security Division and OFAC for alleged violations of U.S. economic sanctions against North Korea.
  • Conducted an internal investigation of a European payment services company related to possible violations of U.S. economic sanctions against Iran.
  • Conducted a comprehensive risk assessment and internal investigation for a foreign agricultural product manufacturing company related to U.S. economic sanctions on Iran in response to a joint inquiry from OFAC and the U.S. State Department.
  • Counseled a U.S.- based international restaurant franchisor on issues with franchisee operations in Latin America involving OFAC and State Department Magnitsky sanctions.
  • Conducted a cross-border sanctions internal investigation for a global logistics provider.
  • Advised several global accounting firms in exiting Russia following imposition of OFAC sanctions.
  • Conducted a cross-border sanctions internal investigation for a large French company.
  • Advise a UK software company serving the airline industry with regard to its compliance with sanctions laws.
  • Advised a Latin American steel producer regarding sanctions matters.
  • Conducted a sanctions risk assessment for an Australian mining company.
  • Conducted a sanctions risk assessment for a Norwegian energy company.
  • Advised a European multinational company in its acquisition of a medical device company, including diligence of the target company’s exposure to certain export controls and economic sanctions risks.
  • Represented a Chinese shipping line regarding sanctions impose on the company’s tanker fleet.
  • Represented one of the world’s leading technical advisory and classification firms, on international sanctions, in light of its previous role providing safety certification, verification, and technical expert services on the Nord Stream 2 pipeline.
  • Represented a major maritime flag state and vessel mortgage holder in connection with an OFAC actions against ship-owners smuggling petroleum in violation of Iran sanctions.
  • Prepared guidelines for U.S. and foreign affiliates of a Fortune 500 healthcare company on compliance with U.S. sanctions laws.
  • Advised Chinese firm in the services sector on potential U.S. secondary sanctions implications from its work for Russia companies.
  • Conducted a cross-border sanctions internal investigation for a global logistics provider.
  • Conducted a cross-border sanctions internal investigation for a large French company.
  • Conducted a sanctions internal investigation for a large European manufacturer.
  • Conducted a sanctions risk assessment for an Australian mining company.
  • Conducted a sanctions risk assessment for a Norwegian energy company.