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Image: Sam Kleiner

Sam Kleiner

Partner, Litigation Department

New York

Phone: +1-212-318-6232
Fax: +1-212-752-3772

Overview

Sam Kleiner is a partner in the Investigations & White Collar Defense practice and Sanctions and Anti-Money Laundering group in the New York office. Sam’s practice focuses on regulatory enforcement defense, white-collar criminal defense, compliance counseling and complex litigation, frequently with a cross-border dimension. He regularly represents the world’s largest banks, fintech companies, investment funds and technology companies across a range of issues, including economic sanctions, anti-money laundering (AML), Bank Secrecy Act (BSA) and data privacy matters.

Sam is a leading authority on sanctions and AML issues. He serves as vice chair of the American Bar Association’s International Anti-Money Laundering Committee and has been a term member of the Council on Foreign Relations. He is an active thought leader and serves on the banking editorial board for Law360. His articles have appeared in Bloomberg Law, Law360, Corporate Compliance Insights and CLS Blue Sky Blog. He regularly provides training to legal and compliance departments at major financial institutions and speaks to industry groups such as the American Bankers Association and the Institute of International Bankers. 

Sam previously served as a senior advisor to the general counsel and the undersecretary for terrorism and financial intelligence at the U.S. Department of the Treasury. During this experience, Sam advised on sanctions, anti-money laundering, CFIUS and litigation matters. Notably, he was awarded the Treasury Department’s Exceptional Service medal by Secretary Janet Yellen. He also previously served as a senior deputy associate counsel at the White House and as a law clerk law clerk to Honorable Gerard E. Lynch of the U.S. Court of Appeals for the Second Circuit. Prior to joining Paul Hastings, Sam was of counsel at another leading global law firm, where he was part of the Litigation and Economic Sanctions & AML practices. 

Sam is the author of the best-selling book, The Flying Tigers, published by Penguin Random House. Inspired by his grandfather’s service in World War II, Sam’s book tells the story of American pilots in China in World War II. It was featured in national media, including The Wall Street Journal and CNN, and described by critics as “read[ing] like an adventure story” and a “terrific” book that brings the pilots’ “compelling stories” to life. 

Sam earned his J.D. from Yale Law School, where he was a Coker Fellow in constitutional law. He received his B.A. cum laude from Northwestern University, where he was elected to Phi Beta Kappa and also received a D.Phil. in International Relations from the University of Oxford, where he was a Marshall Scholar. Sam is admitted to practice in New York. 

Accolades

  • Treasury Exceptional Service Medal, U.S. Department of the Treasury

Education

  • Yale Law School, J.D.
  • University of Oxford, D.Phil (Marshall Scholar)
  • Northwestern University, B.A. (cum laude, Phi Beta Kappa)

Representations

  • TD Bank in a number of significant matters, including its resolutions with the U.S. Department of Justice (DOJ) over the bank’s compliance with AML requirements as part of the bank’s global resolution with U.S. government and regulatory authorities.
  • A U.S. fintech company in DOJ and other agency investigations regarding alleged anti-money laundering and sanctions violations.
  • A major global financial services institution in a DOJ sanctions investigation, including concerning Russia-, Belarus- and Ukraine-related sanctions matters.

*Matters may have been completed before joining Paul Hastings.

Engagement & Publications

Publications

  • “US Targeting TCO’s Role in Scam Centers,” Corporate Compliance Insights, Co-Author (March 31, 2026) 
  • “The State of OFAC Sanctions Enforcement in 2025-26,” Corporate Compliance Insights, Co-Author (March 16, 2026)
  • “2 OFAC Sanctions Actions Highlight PE Compliance Risk,” Law360, Co-Author (Jan. 15, 2026)
  • “Fraud, MiCA and Shadow Banking: Compliance in 2026,” MoneyLaundering.com, Contributor (Dec. 29, 2025)
  • “Lessons From Crackdown On Mexican Banks With Cartel Ties,” Law360, Co-Author (July 22, 2025)
  • “DOJ Data Security Rule Has Ticking Clock for Companies to Comply,” Bloomberg Law, Co-Author (May 20, 2025)
  • “How to Navigate Risks for Firms on Cartel-Related Activities,” Bloomberg Law, Co-Author (June 5, 2025) 
  • The Flying Tigers: The Untold Story of the American Pilots Who Waged a Secret War Against Japan, Author (2018)    

Speaking Engagements

  • “Waves of Change: The Global State of AML Regulation,” American Bar Association 2026 International Law Section Annual Conference, Panelist (May 13, 2026)
  • “Resolving Ethical Dilemmas in the Context of Sanctions Compliance Decision-Making,” AACI’s 16th Annual AML & Sanctions Compliance for the Insurance Industry Conference, Panelist (March 4, 2026)
  • “Bridging the Communication Gap Between Law Enforcement and Financial Institutions,” 22nd Puerto Rican Symposium on Anti-Money Laundering, Panelist (Feb. 27, 2026)
  • “What’s New Under the New Administration – Sanctions Update,” Institute of International Bankers’ 2025 Financial Crimes Conference, Moderator (Sept. 9, 2025)
  • “Making Sense of the AML Regulations & the Art Market,” Center for Art Law, Panelist (May 15, 2025)
  • “We’re Not Done with Beneficial Ownership! An Overview of the Latest Risks and Concerns,” American Bar Association Financial Crimes Enforcement Conference, Panelist (Oct. 8, 2024)
  • “Financial Services and Economic Statecraft,” National Security, Sanctions and Export Controls: Compliance, Investigations and Enforcement Conference, Panelist (May 23, 2024)

Involvement

  • Banking Editorial Board – Law360 Editorial Advisory Board (2026) 
  • Vice Chair of the International Anti-Money Laundering Committee – American Bar Association (2025)
  • Advisory Committee Member – United Jewish Appeal of New York 

Languages

English


Admissions

New York Bar


Education

Yale Law School, J.D. 2015

University of Oxford, Ph.D. 2012

Northwestern University, B.A. 2009