Practice Areas

Anti-Money Laundering & Economic Sanctions

Anti-money laundering (AML) and sanctions are top U.S. and global enforcement priorities. The failure to meet increasingly complex expectations can result in investigations, billion-dollar fines and reputational damage. Our team provides sophisticated AML and sanctions counsel to banks, fintechs, digital asset companies and other multinational clients.

Deep Government Experience

Our team is our primary value proposition. We formulated and enforced AML and sanctions policies while serving in key government posts, enabling us to provide unique insights and strong regulatory relationships.

Our team includes:

The former U.S. Treasury deputy general counsel responsible for overseeing the legal offices of the Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC), as well as a former Treasury senior advisor for AML and sanctions issues.
The former deputy head of enforcement at FinCEN, as well as a former OFAC enforcement officer.
The former principal deputy chief of DOJ’s Money Laundering and Asset Recovery Section (MLARS, now MNF), which is responsible for AML/sanctions investigations of financial institutions.
The former principal deputy assistant attorney general of DOJ’s Criminal Division.
Former counsel at the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board, the New York State Department of Financial Services (NY DFS) and other financial regulators.

Our team also includes experienced lawyers in the U.K., the EU and Asia, allowing us to provide multijurisdictional advice and defense. We work seamlessly with our export controls, bank regulatory, fintech and consumer protection teams, as well as our broader white collar defense practice.

Regulatory Advice and Compliance Counseling

Our primary objective is to help clients avoid unwanted regulatory attention. To this end, we assist with risk assessments and compliance upgrades and partner with clients to anticipate, interpret and implement rapidly evolving regulatory expectations. We have helped, for example, clients plan for imminent regulatory changes (including FinCEN’s proposed program and stablecoin rules), address government priorities (including around cartels, trade-based money laundering and the growing focus on fraud) and integrate AI into compliance processes. We also advise on correspondent banking, KYC/CIP/CDD implementation issues, the Travel Rule, SAR-filing decisions and other areas that continue to pose risk.

We have also helped clients adapt to the growing number of Foreign Terrorist Organization (FTO) designations and OFAC’s evolving approaches to Iran, China, Russia, Venezuela and Cuba. We have extensive experience counseling on sanctions compliance for digital assets. We also have a strong track record of obtaining novel OFAC licenses and submitting voluntary disclosures that result in no penalty.

Examinations and Investigations

In examinations, we are adept at reducing adverse findings and avoiding escalations to enforcement. When the government initiates an investigation, we are tireless, creative and efficient at delivering the best results possible for our clients. Our team has successfully handled some of the largest criminal and regulatory enforcement matters in this space. We have represented clients in AML and sanctions matters before the DOJ (including various U.S. Attorneys’ Offices), Treasury (FinCEN and OFAC), federal banking agencies (including the OCC, Federal Reserve and FDIC), congressional committees and state authorities such as the New York Department of Financial Services (NY DFS) and California Department of Financial Protection and Innovation (CA DFPI). We have also handled investigations internationally before the U.K. Financial Conduct Authority (FCA), U.K. Serious Fraud Office (SFO) and U.K. Office of Financial Sanctions Implementation (OFSI), among others. We have also represented clients in parallel civil lawsuits involving AML and sanctions matters, including under the Anti-Terrorism Act.

Recognition

Band 1 – White-Collar Crime & Government Investigations (District of Columbia), Chambers USA (2026)
Nationwide Corporate Crime & Investigations: The Elite, Chambers USA (2026)
Nationwide International Trade: Economic Sanctions and Export Controls, Chambers USA (2026)
Compliance Practice Group of the Year, Law360 (2022, 2023)
Finalist – Most Impressive Investigations Practice of the Year, Global Investigations Review (2024)
White Collar Practice Group of the Year, Law360 (2021, 2022)

Representative Experience

Banks and Broker-Dealers:

A UAE financial institution in criminal and civil sanctions matters before the DOJ, OFAC, the Federal Reserve, the NY DFS, the FCA and the U.K. Prudential Regulation Authority. Most notably, we successfully defended our client against a $750 million OFAC fine with novel legal and policy arguments, based largely on statute-of-limitations grounds, resulting in a Finding of Violation with zero financial penalty.
A top five global bank in an investigation by the U.S. Attorney’s Office for the Southern District of New York focused on U.S. dollar-clearing activity and related AML and sanctions controls, and in parallel investigations by the Federal Reserve and the NY DFS regarding alleged sanctions violations.
A major U.S. bank in responding to DOJ and OFAC investigations regarding business activities involving Russia and Ukraine.
A major national bank in a number of significant matters, including its resolutions with DOJ regarding the bank’s compliance with AML requirements as part of the bank’s global resolution with U.S. government and regulatory authorities.
Shinhan Bank America in the successful settlement of AML investigations by the NY DFS, FDIC and FinCEN.
Industrial and Commercial Bank of China (ICBC) and its New York branch in the successful resolution of AML and CSI-related inquiries by the NY DFS and the Federal Reserve.
National Bank of Pakistan and its New York branch in a successful resolution of sanctions/AML compliance investigations by the NY DFS and the Federal Reserve.
A major global financial services institution in a DOJ sanctions investigation, including matters concerning Russia-, Belarus- and Ukraine-related sanctions.
A Mexican financial institution in a comprehensive review of the bank’s AML program.
A consortium of international banks in connection with their ongoing obligations to comply with economic sanctions under multiple U.S., EU and other sanctions regimes and their credit exposure to sanctioned companies.
A large U.S. bank in an industry-wide congressional investigation of banks’ historic business in a higher-risk jurisdiction.
Multiple financial institutions in OFAC licensing applications, requests for interpretive advice, delisting petitions, and the filing of voluntary disclosures and responses to document requests.
A major electronic broker in resolving a complex OFAC sanctions investigation for $11.8 million despite potential exposure exceeding $5 billion.

Fintech, Payments and Digital Asset Companies:

A major U.S. fintech company in a DOJ investigation regarding AML and sanctions compliance involving fiat and crypto-related services.
A major payment platform in a DOJ investigation regarding AML, which was successfully resolved with a full declination.
Multinational cryptocurrency exchanges in connection with BSA/AML compliance issues, self-disclosures to OFAC and responses to DOJ and regulatory subpoenas.
A co-founder of an algorithmic stablecoin in defending against allegations of fraud, conspiracy and money laundering before the SEC and DOJ.
A major U.S. fintech company in a resolution of an AML, sanctions, cybersecurity and consumer protection investigation by NY DFS, which included a monitorship.
A global cryptocurrency exchange in the resolution of an AML and sanctions investigation by FinCEN and OFAC.
Numerous U.S. and non-U.S. fintech and digital asset companies on AML and sanctions policy design, program enhancements, regulatory exams, incorporation of AI into compliance and ongoing compliance strategy.
Multiple national trust banks, NY DFS state-chartered trusts and bitlicensees in drafting and enhancing AML and sanctions policies, procedures and controls to support licensing applications and in responding to NY DFS requests for information.
Global stablecoin issuers on AML and sanctions product risk assessments, enhancements to AML/sanctions policies and procedures, and transaction monitoring model validations.

Multinational Corporations:

A leading European technology company in reaching a global resolution with DOJ, OFAC and the Commerce Department’s Bureau of Industry and Security (BIS) regarding alleged sanctions and export control violations.
A 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.
A 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.
A major UAE-based oil and gas refiner and trader in connection with blocked payments relating to an ongoing OFAC and DOJ investigation into Iranian oil trading.
An Asia-based manufacturer in the successful resolution of a DOJ investigation into potential sanctions and bank fraud violations regarding alleged business dealings with North Korea.
A U.K.-based services company in a DOJ investigation regarding potential Iran-related sanctions violations.
A major AI company in obtaining a novel license from OFAC.
A global consumer goods company in a resolution of potential sanctions violations with OFAC. A leading global tobacco and nicotine goods company in the recent successful dismissal of an ATA lawsuit.
A major European consulting firm in conducting its annual AML risk assessment for regulated and unregulated activity in both the U.S. and EU.
A global oil and gas company in conducting an AML and sanctions risk assessment across its product lines.
The CEO of a global technology company in a criminal investigation before the DOJ for alleged money laundering and BSA/AML violations.