Anti-Money Laundering (AML)

We routinely work with clients to conduct AML risk assessments, implement appropriate risk-based compliance programs, review the effectiveness of these programs; seek administrative rulings from appropriate regulators; file Suspicious Activity Reports (SARs); draft self-disclosures; provide training on AML laws and regulations as well as internal policies and procedures; provide day-to-day guidance on transaction-specific issues; and respond to government investigations.

We also work with industry groups, including traditional and non-traditional financial institutions, to develop AML best practices. Together our Government Affairs, Corporate, Financial Services, Insurance and Reinsurance, Trade, and White Collar and Regulatory Enforcement groups help trade associations and other organizations address, comment on, and influence laws, policies and enforcement actions by relevant regulatory agencies.

Office of Foreign Assets Control (OFAC)

Parallel to our AML practice, we assist a wide array of multinational and U.S. clients in developing and maintaining risk-based sanctions compliance programs. Where appropriate, we also assist clients in developing export controls policies and procedures. As part of our comprehensive sanctions compliance program, we guide clients on drafting and filing licensing applications, voluntary self-disclosures, requests for advisory opinions, and responses to subpoenas. For our cross-border clients, we work to ensure that compliance policies and procedures address blocking statutes, data privacy concerns, and local sanctions requirements. As active participants in numerous trade associations, we also assist in drafting comments to legislation or proposed rules to ensure clients' concerns are appropriately expressed and, where possible, addressed.