Anti-Money Laundering /Sanctions Compliance & Enforcement

www.debevoise.com

Debevoise’s market-leading AML / Sanctions Compliance &

Enforcement practice provides expert and practical advice on

anti-money laundering and economic sanctions matters to a wide

range of institutions—including multinational banks, securities

broker-dealers, asset managers, consumer credit and travel-related

service providers—as well as leading industry associations. Our

attorneys draw upon extensive experience (both from the private

sector and in government). We work with clients in all types of

adversarial proceedings, ranging from contentious regulatory

examinations to administrative enforcement actions to civil and

criminal litigation.

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Debevoise assists clients in:

• reviewing, revising and implementing AML and sanctions-related compliance policies and procedures (including with respect to compliance programs that need to address multi-jurisdictional requirements);

• performing compliance assessments (including with respect to the structuring of compliance in multinational organizations);

• providing AML and sanctions training;

• leading internal investigations regarding potential AML, sanctions and related compliance issues;

• responding to regulatory and law-enforcement inquiries regarding AML and sanctions matters; and

• defending proceedings and enforcement actions instituted by the full range of international enforcement agencies .

The Debevoise team works collaboratively across offices around the world and draws on the experience and expertise of members of the firm’s Banking, Financial Institutions, Litigation and White Collar & Regulatory Defense practices. The team includes Michael B. Mukasey, former Attorney General of the United States and Chief Judge of the U.S. District Court for the Southern District of New York; Lord Peter Goldsmith, former Attorney General of the United Kingdom; David A. O’Neil, former Acting Assistant Attorney General for the Criminal Division and former Deputy Assistant Attorney General for the Fraud Section at the Department of Justice; and a team of other senior lawyers with other government experience. In addition to our work on behalf of clients, we are thought leaders on AML and sanctions issues. We write and speak regularly on these topics, including as authors of the leading treatise on AML and OFAC requirements for non-U.S. banks doing business in the United States. Within the past year, members of the team have spoken at leading industry conferences in London, Paris, Moscow, New York, Hong Kong and Singapore.

We also serve as AML and sanctions counsel to leading trade associations such as the Financial Services Roundtable and Securities Industry and Financial Markets Association.

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Examples of AML/Sanctions Compliance & Enforcement MattersCorporate Advisory Work:

• A number of US and non-US clients on how to structure transactions involving Russian sectorally sanctioned counterparties. In these cases, we have advised clients on how to structure terms so that they are not engaging in new debt or equity issued by the sectorally sanctioned entities; we also have considered how the so-called “50% rule” applies to JVs and other structures.

• A number of bank clients and others on implications of dealings with entities that are headed by sanctioned individuals. We have, in these instances, counseled on how to avoid direct dealings with those individuals (which presents sanctions risks) but on how to deal with the non-sanctioned entities that these individuals head.

• An Indian company in the sanctions implications of its involvement with a Middle-Eastern oil company with operations in U.S. sanctioned jurisdictions.

• Undertaking a sanctions-focused acquisition due diligence of a major insurance business for an international insurance company.

• Advising a major international financial services company on the potential EU sanctions risks arising from an acquisition of a UK-listed company.

• Advising on EU sanctions consequences for a major oil and gas project in the Barents Sea.

• Advising a Russian company on the scope of the EU capital market restrictions in respect of a proposed share issuance.

• Advising a Leading U.S. bank in the acquisition of a financial technology firm and the integration of that firm into its AML/BSA compliance framework.

• Advising on EU sanctions aspects of financing documents for a variety of corporate clients.

Compliance Advice:

• Ongoing EU sanctions advice on recent sanctions developments and specifically their impact on travel business for an international travel services company.

• Creation and implementation of a bespoke sanctions compliance policies and procedures and employee training modules for the UK subsidiary of a media organisation.

• Ongoing EU sanctions advice and updating sanctions policies in light of recent sanctions developments for a major Russian private equity investment firm.

• Ongoing EU sanctions advice for a major Russian telecommunications company.

• Ongoing EU sanctions advice in relation to business activities in jurisdictions subject to EU sanctions for a major Russian manufacturer.

• Providing sanctions training and workshop for a Greek company.

• Ongoing advice to major corporates, banks, insurers and other financial institutions regarding the ability to engage in Iranian, Russian and other transactions without violating EU and U.S. sanctions.

Regulatory Defence:

• Advising a large financial institution in an investigation conducted by the DOJ, FinCEN and federal banking regulators on money laundering charges.

• Representing a client before the Office of Financial Sanctions Implementation (“OFSI”) in relation to self-reported sanctions issues relating to Syria, resulting in a “no-action” decision by OFSI.

• Representing a client before OFSI and HMRC relating to potential sanctions issues in the Democratic People’s Republic of Korea.

• Advising a leading U.S. bank in a series of OFAC self-disclosures and settlements.

• An investigation into potential financial and export control sanctions issues in Iran for an international manufacturer.

• Advising a Leading national bank in an AML investigation by New York State and federal authorities in an investigation related to AML and fraud.

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Awards and Recognitions

Band 1 firm for Corporate Investigations – Global-wide Chambers Global, 2018 Banking Practice Group of the Year Law360 Awards, 2017 Ranked in the top tier in London for Financial Crime: Corporates

“Debevoise is top of the list when it comes to corporate investigations and regulator engagement.”

“The team’s particular strength is their hands-on experience and very strong knowledge of the regulatory framework. They are at the top because they have knowledge and experience, they work hard and they deliver.” Chambers UK, 2019 Recognized as a leading practice in the “Sanctions Law Firm of the Year, Europe” category. WorldECR Awards, 2018 Band 1 firm for White-Collar Crime & Government Investigations Chambers USA, 2018 Recognized as a leading practice in the “Sanctions Law Firm of the Year, U.S.A.” category. WorldECR Awards, 2016 Named as one of the top investigations practices in the world in the GIR 30. Global Investigations Review

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Key Contacts

Lord (Peter) Goldsmith QC, PCPartner, London phgoldsmith@debevoise.com +44 20 7786 9088

London

Karolos SeegerPartner, London kseeger@debevoise.com +44 20 7786 9042

Jane ShvetsPartner, London jshvets@debevoise.com +44 20 7786 9163

Konstantin Bureiko Associate, London kbureiko@debevoise.com +44 20 7786 5484

Alan KartashkinPartner, Moscow akartashkin@debevoise.com +7 495 139 4004

Moscow

Matthew L. BibenPartner, New York mlbiben@debevoise.com +1 212 909 6606

New York

Helen V. CantwellPartner, New York hcantwell@debevoise.com +1 212 909 6312

Paul L. LeeOf Counsel, New York pllee@debevoise.com +1 212 909 6955

Carl MicarelliCounsel, New York cmicarelli@debevoise.com +1 212 909 6813

Michael B. MukaseyOf Counsel, New York +1 212 909 6589

David SarrattPartner, New York dsarratt@debevoise.com +1 212 909 6864

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New York (Cont’d)

Bruce E. YannettPartner, New York beyannett@debevoise.com +1 212 909 6495

David G. SewellCounsel, New York dsewell@debevoise.com +1 212 909 6755

Arian M. JuneCounsel, Washington, D.C. ajune@debevoise.com +1 202 383 8053

Robert T. DuraAssociate, Washington, D.C. rdura@debevoise.com +1 202 383 8247

Washington, D.C.

Satish M. KiniPartner, Washington, D.C. smkini@debevoise.com +1 202 383 8190

Kara BrockmeyerPartner, Washington, D.C. kbrockmeyer@debevoise.com +1 202 383 8120

David A. O’NeilPartner, Washington, D.C. daoneil@debevoise.com +1 202 383 8040 +1 202 809 1995

Philip RohlikCounsel, Shanghai prohlik@debevoise.com +86 21 5047 1800 x 218 +86 21 5047 0788

Shanghai

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