Sanctions, AML, Export Controls and National Security

• Top five global bank in an investigation by the Southern District of New York U.S. Attorney’s Office related to U.S. dollar-clearing activity and related anti-money laundering (AML) controls, and in an investigation by the Federal Reserve and the New York Department of Financial Services regarding alleged sanctions violations.
• Shinhan Bank America in the successful settlement of AML inquiries involving the New York Department of Financial Services, FDIC and FinCEN.
• National Bank of Pakistan and its New York branch in a successful resolution of sanctions/AML compliance investigations by the New York Department of Financial Services and Federal Reserve.
• 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 Department of Financial Services and Federal Reserve.
• Major U.S. fintech company in DOJ and state regulatory investigations regarding anti-money laundering and sanctions compliance involving fiat and crypto-related services.
• Major non-U.S. bank in a review of its private bank’s potential exposure to U.S. sanctions against Russia.
• Major U.S. manufacturing company in internal investigations and self-disclosures of potential Iran and Russia-related sanctions and export control violations, resulting in no public enforcement response.
• Leading technology company and a leading financial services company in multidisciplinary reviews of their compliance programs, including in the areas of sanctions and AML compliance.
• 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.
• U.K.-based services company in a DOJ investigation regarding potential Iran-related sanctions violations.
• U.S.-based movie studio in regulatory advice and counterparty diligence regarding sanctions against Russia.
• Multiple U.S. and non-U.S. clients — across financial services, entertainment, sports, luxury goods and technology — in OFAC licensing applications, requests for interpretive advice, de-listing petitions, and the filing of voluntary disclosures and responses to document requests.
• Major non-U.S. technology company in engaging with multiple U.S. government agencies regarding privacy, data security and national security concerns regarding an app.
• Several Asia-based technology companies in responding to investigations by the Commerce Department under the information and communications technology and services (ICTS) executive order.
• Indenture trustee and collateral agent in litigation in the District Court for the Southern District of New York concerning the enforceability of senior secured notes issued by Petroleos de Venezuela, S.A., and related sanctions issues.
• Multiple asset managers in connection with due diligence and advice on compliance and regulatory issues in potential transactions spanning the areas of sanctions/AML, consumer financial protection and cryptocurrency.

CFPB and Consumer Protection

• Major nonbank company in a favorable settlement with the CFPB regarding alleged violations of Fair Credit Reporting Act and UDAAP requirements.
• Major U.S. technology company in a federal lawsuit challenging the CFPB’s designation of the company for supervision based on its “risks to consumer” authority and in prior internal agency proceedings (the CFPB ultimately withdrew the designation).
• Several U.S. banks in a comment letter to the CFPB regarding its credit card late fee rulemaking proposal.
• Major U.S. bank in connection with a favorable, no-penalty settlement with the CFPB regarding credit card practices and follow-on settlements with state attorneys general.
• U.S. multinational technology company in a CFPB inquiry into the business practices of so-called “Big Tech” companies operating payments products.
• Major technology company in resolving allegations by the D.C. attorney general regarding allegedly deceptive tipping practices.

Congressional Investigations

• Major U.S. bank in connection with an industry-wide House committee investigation regarding financial dealings with a higher-risk jurisdiction.
• Major U.S. bank in successfully defending a federal lawsuit brought by a customer for alleged violations of the Right to Financial Privacy Act in connection with a congressional investigation.
• National trade association in connection with a House investigation regarding climate change as well as preparing the CEO for successful testimony in a committee hearing.
• Major U.S. bank in an investigation by the House Select Committee on the Coronavirus regarding the operation of the Paycheck Protection Program (PPP) and concerns regarding access by minority and low-income borrowers.
• U.S. multinational technology company in connection with its response to an investigation by the House Oversight and Reform Committee related to a natural disaster and worker safety at the retailer’s facilities, as well as a high-profile investigation by a Senate committee regarding worker safety.
• Former cabinet official in high-profile congressional inquiries.
• U.S. bank with regard to a congressional inquiry into its actions and policies towards firearms.
• U.S. apparel corporation in responding to requests from the House Select Committee on China in relation to the sourcing of materials from the Uyghur region.

False Claims Act

• U.S. equipment manufacturer in a long-running DOJ False Claims Act criminal and civil investigation.
• Private equity firm in connection with a False Claims Act civil investigation by DOJ in the healthcare industry, which resulted in a formal declination.
• Multiple organizations in False Claims Act investigations regarding COVID-era PPP loans.

Other Investigations and Litigations

• Multinational technology conglomerate in one of the largest publicly announced racial equity audits, which analyzed the company’s overall policies, practices, programs and initiatives to determine their racial impacts on the company’s wage-earning employees.
• Blackrock in an internal investigation into former employees’ allegations of sexual harassment and discrimination.
• Citigroup and its affiliates in successfully defeating class certification in an ongoing multidistrict putative class action alleging that Citi and other banks conspired to reduce potential competition in interest rate swap trading, as well as in a related CFTC investigation.
• Binance in the dismissal of a lawsuit brought by a former consultant alleging conversion, unjust enrichment and negligence related to cryptocurrency allegedly confiscated from his account after the consulting arrangement ended; and federal and state court lawsuits regarding the operation of its exchange.
• Major U.S. bank in an internal investigation and accountability review regarding allegations of potential employee misconduct and compliance program failures.
• Major private equity firm in connection with allegations of internal misconduct, conflicts of interest and theft of proprietary information.
• American Bar Association in an amicus brief filed in the Bruen case in the U.S. Supreme Court concerning the constitutionality of New York’s firearm licensing law.