Economic sanctions are in the headlines more than ever. From the Iran nuclear deal, to the conflict in Ukraine, to the warming of relations between the United States and Cuba, foreign policymakers are employing economic sanctions with increasing frequency and in innovative ways never seen before. Meanwhile, regulators are keeping pace, overseeing a surge in enforcement and record-breaking fines imposed on some of the world’s largest financial institutions and multinational corporations. Sanctions-related penalties now routinely figure in the hundreds of millions—and even billions—of dollars, underscoring the importance of a strong compliance program, guided by experienced counsel with a nuanced understanding of complex and changing laws and regulations.
Cadwalader’s White Collar Defense and Investigations group has represented aerospace and defense companies, industrials, oil and gas companies, petrochemical companies, financial institutions, trading entities, non-government organizations, and individuals regarding the application of U.S. economic sanctions laws and regulations issued by the Department of the Treasury’s Office of Foreign Assets Control (OFAC), the Department of Justice, and the Department of State. This includes responding to, defending, and settling OFAC and Department of Justice enforcement actions, preparing and presenting voluntary disclosures, drafting and securing OFAC licenses and exemptions (including the release of frozen assets), assisting in the preparation of mandatory reports to OFAC, responding to regulators on economic sanctions issues, advising on potential sanctions implications of complex business transactions, and developing and implementing global sanctions policies and compliance programs.