Economic Sanctions & Anti-Money Laundering

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Overview

RK&O has significant expertise advising clients with respect to evolving U.S. economic sanctions and anti-money laundering requirements, which are often at issue in our international compliance counseling, government enforcement and internal investigations assignments. Our extensive experience in each of these areas informs the other, allowing us to represent our clients across a full complement of cross-border issues. more +

We have a proven record of navigating difficult regulatory and criminal sanctions and AML issues, from internal investigations and criminal and regulatory inquiries to providing real-time compliance advice in relation to the latest hot-button developments. We are adept at working closely with clients and regulators to develop practical solutions to address evolving regulations, products and technologies. Our team provides timely, multi-level counseling in connection with the most important and relevant issues of the day, providing clients with a thorough understanding of developing laws and regulations and offering real-world advice regarding risk assessment and mitigation.

We have developed a sterling reputation for our expert services, providing ongoing compliance advice, conducting internal investigations and defending clients in enforcement matters for many of the world’s most respected financial institutions, companies and boards of directors. At our core, we drive solutions and are known for delivering thoughtful and creative resolutions to the complicated challenges facing our clients. 

RK&O’s Economic Sanctions & AML 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 compliance 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. 
  • Various international clients regarding compliance with U.S. sanctions laws in relation to investments in and lending to third country entities doing business with Cuba.
  • A non-U.S. financial institution in relation to compliance with U.S. sanctions law in the development of a recusal and delegation policy for U.S. person employees in relation to Cuba-related transactions.
  • A global hedge fund regarding a large transaction involving investment in a non-U.S. shipping company with Cuba-related shipping lines.
  • A Canadian financial institution on compliance with overlapping OFAC and New York State Comptroller requirements.
  • Senior employees of a French financial institution in a criminal investigation into potential violations of Cuba sanctions.
  • Financial services clients regarding the application of Russian and Venezuelan sanctions to securities trading and fixed-income trading.
  • A global hedge fund in a successful OFAC licensing application relating to a complex series of transactions involving Iranian nationals.
  • A financial services client in an OFAC inquiry relating to a transaction by a non-U.S. portfolio company with a counterparty alleged to be a front for an Iranian sanctioned entity.
  • Two dozen employees (including senior business and compliance personnel) of a large UK-based global bank in an ongoing DOJ-MLARS, DFS, NY Fed, DANY, and New York AG investigation relating to Iran sanctions and transaction monitoring issues (including detection scenario effectiveness), including numerous DOJ et al. and DFS monitor interviews of our clients.
  • Four internal auditors of a large UK-based global bank in DOJ monitor interviews relating to Iran sanctions compliance.
  • A global compliance head in an ongoing USAO-SDNY investigation of a European financial institution relating to Iran sanctions.
  • A leading global NGO in support of its advocacy before the Departments of State and Treasury regarding the Global Magnitsky Act.

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