Representative Engagements

• A top-five global bank in an investigation by the Manhattan U.S. Attorney’s Office related to U.S. dollar-clearing activity and related anti-money laundering (AML) controls and in a prior investigation by the Federal Reserve and the NY DFS regarding alleged sanctions violations.
• Shinhan Bank America in the successful resolution of BSA/AML inquiries by the NY DFS the FDIC, and FinCEN.
• Citigroup in a multi-year federal grand jury investigation of its compliance with BSA/AML requirements that resulted in a non-prosecution agreement and a significantly reduced penalty.
• Industrial and Commercial Bank of China (ICBC) and its New York branch in the successful resolution of BSA/AML and CSI-related inquiries by the New York State Department of Financial Services and the Federal Reserve.
• The National Bank of Pakistan and its New York branch in a successful resolution of BSA./AML and sanctions inquiries by the New York Department of Financial Services and Federal Reserve.
• Standard Chartered Bank in resolving a six-year sanctions investigations into its historic violations and control deficiencies by six U.S. federal and state agencies and the UK’s Financial Conduct Authority (FCA).
• A U.S. fintech company in DOJ and other agency investigations regarding alleged BSA/AML and sanctions violations.
• Several Asia-based technology companies in responding to investigations by the Commerce Department under the information and communications technology and services (ICTS) executive order.
• A major U.S.-based manufacturer in the internal investigation of whistleblower allegations regarding alleged Iran sanctions violations, and a subsequent voluntary self-disclosure to OFAC that resulted in a no-action letter.
• A U.S. based movie studio in regulatory advice and counterparty diligence regarding Russian sanctions.
• A luxury apparel brand in responding to an OFAC subpoena regarding potential indirect sales implicating Russian sanctions.
• A major non-U.S. bank in a review of its private bank’s potential Russian sanctions exposure.
• A major ecommerce company in ongoing sanctions and export control advice and compliance enhancements.
• An Asia-based manufacturer in connection with the resolution of a DOJ investigation into potential sanctions and bank fraud violations regarding alleged business dealings with North Korea.
• A large U.S. bank with respect to multiple DOJ and OFAC sanctions investigations.
• A global Asia-based technology company in ongoing sanctions, export control, supply chain, and anti-money laundering advice.
• Multiple Chinese banks in connection with BSA/AML and sanctions investigations and regulatory advice, training and compliance counseling.
• Multiple U.S. and non-U.S. clients in interactions with OFAC regarding licensing applications, requests for interpretive advice, de-listing requests, and the filing of voluntary disclosures and subpoena responses.
• A major non-U.S. technology company in engaging with multiple U.S. government agencies regarding privacy, data security, and national security concerns regarding a mobile app.
• Multiple private equity firms and other companies in connection with sanctions and BSA/AML diligence for acquisitions and investments, as well as strategic regulatory advice relating to market entry.
• A major U.S.-based cruise line in connection with OFAC and other U.S. regulatory issues, including initiating travel to Cuba by cruise ships.
• An international music publisher in connection with OFAC-related matters involving Cuba.
• A natural resources company in an internal investigation regarding sanctions and bribery allegations.