Anti-Money Laundering & Economic Sanctions

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Overview

Government agencies continue to expand anti-money laundering (AML) laws around the globe, thus intensifying compliance risks for financial institutions, private fund advisors and multinational companies. Similarly, the U.S. government is increasingly turning to economic sanctions programs to influence foreign policy and achieve national security objectives. At RK&O, we help our clients understand the intersection of AML rules, sanctions policies, anti-corruption laws and the ever-changing compliance and enforcement landscape.   more +

RK&O counsels financial institutions, private fund advisors and multinational companies on regulatory matters and compliance risks relating to the AML laws, including with respect to Know Your Customer (KYC) requirements and other issues arising under the Bank Secrecy Act and the USA PATRIOT Act. While certain of our clients may not formally be subject to AML requirements, we provide forward-looking, pragmatic advice to clients interested in designing policies, procedures and controls that seek to mitigate long-term risk in a regulatory environment that changes by the day.  

Multinational financial institutions, companies and investors in the global marketplace also must develop strategies to ensure that their activities are consistent with economic sanctions implemented by the Office of Foreign Assets Control (OFAC). We regularly counsel our clients with regard to the frequently changing OFAC rules, requirements and restrictions that can impact international transactions. We perform extensive and industry-specific due diligence of investment targets and transactional structures to mitigate risk and avoid potential issues arising under OFAC’s sanctions regime. Additionally, when the necessity arises, we interact directly with OFAC on related licensing issues.

RK&O’s AML & Economic Sanctions expertise is closely tied to our Compliance and Anti-Corruption practices, allowing us to provide critical counseling and advice in connection with internal and regulatory investigations. Our team, which includes both former federal prosecutors and ACAMS-certified AML specialists, has established practical experience handling these matters both domestically and abroad. 

Experience

  • A Latin American sports marketing and production company in regards to the international FIFA investigation into allegations of bribery, fraud and money laundering. 
  • A multi-billion dollar investment fund in connection with anti-corruption and economic sanctions issues arising from a significant interest held in a portfolio company whose operations are exclusively in Russia.
  • A hedge fund in connection with OFAC licensing and related economic sanctions issues relating to ongoing litigation in the Middle East over equipment assets serving as collateral to distressed debt.
  • A leading Asian financial services group in connection with the economic sanctions ramifications of a bond issuance.
  • An international financial services firm in connection with an asset forfeiture proceeding and related DOJ investigation into alleged money laundering. 
  • Several major hedge funds with respect to internal investigations and due diligence regarding payments made with joint ventures in Russia, China, Thailand, Bulgaria and India. 

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