Nicole Sayegh Succar is a counsel in Crowell & Moring’s New York office. She is a member of the firm’s International Trade Group and works closely with White Collar & Regulatory Enforcement Group. Nicole provides compliance counseling and investigations services related to U.S. economic sanctions, and the Bank Secrecy Act (BSA), and anti-money laundering laws (AML) and regulations. Nicole is a former sanctions officer with the Office of Foreign Assets Control (OFAC), the U.S. Treasury Department agency responsible for administering and enforcing economic sanctions. While at OFAC, Nicole handled complex matters relating to U.S. sanctions against Russia, Iran, North Korea, Cuba, and Syria.
Before joining Crowell & Moring, Nicole served as a senior vice president and head of U.S. economic sanctions advisory and previously a vice president in the financial crimes division, for one of the world’s largest international financial institutions. In her most recent role, she was responsible for sanctions advisory for the U.S. institution’s business units including global, domestic, private, retail and wealth management banking services. Her responsibilities included management of the bank’s response to sanctions issues related to customers and complex transactions and deals, drafting of responses to OFAC, including voluntary self-disclosures and administrative subpoena responses, and training of staff globally on U.S. Sanctions.
During her time in the financial services industry, Nicole also built key financial crimes compliance capabilities including robust policies, procedures, and due diligence processes, which were adopted across the global organization. Nicole’s success with the U.S. program earned her international assignments as the Asia regional head of sanctions and Latin America regional head of sanctions, where Nicole managed teams of compliance advisory, investigations and screening operations personnel, as well as the implementation of key compliance systems for customer and transaction screening. Through those assignments, Nicole gained invaluable experiences in implementing and managing a global financial crime compliance program across diverse international markets.
In her roles, Nicole also frequently interacted with, and provided formal responses regarding the state of the institution’s financial crimes compliance program, to OFAC, the Federal Reserve Board, the U.S. Treasury’s Office of the Comptroller of the Currency (OCC), and a monitor appointed by the U.S. Department of Justice (DOJ).
With her background at OFAC and financial institution experiences, Nicole offers a strong combination of insightful in-government and private industry experience in sanctions compliance that allows clients to pursue innovative and practical solutions to sanctions and other financial crimes issues.
Nicole has been recognized by Super Lawyers as a "Rising Star" in international trade since 2022.
Recognition
- Super Lawyers: "Rising Star," International Trade, 2022
Affiliations
Professional Activities and Memberships
- Asian American Bar Association of New York (AABANY)
- United States Council for International Business (USCIB)
- Association of Certified Anti-Money Laundering Specialists (ACAMS)—New York Chapter Member, Frequent Event Speaker
- Association of Certified Sanctions Specialists (ACSS)—Member, Government Relations Task Force
Speeches & Presentations
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"Russia Sanctions Two Months In: Where Are We and Where Are We Headed," National Contract Management Association
(April 19, 2022).
Presenters: Caroline Brown, Carlton Greene, Brian McGrath, Anand Sithian, Nicole Succar and Dj Wolff.
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"Analysis of the Evolving US Sanctions on Russia and the Impact on the Loan Market," LSTA University Webinar 2022.
(March 9, 2022).
Speakers: Caroline E. Brown, Dj Wolff, Carlton Greene, Nicole Sayegh Succar, Anand Sithian, and Robert Clifton Burns.
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"Russia-Related Sanctions Developments," Crowell & Moring Webinar
(March 2, 2022).
Speakers: Caroline E. Brown, Carlton Greene, Michelle J. Linderman, David (Dj) Wolff, Lorenzo Di Masi, Anand Sithian, and Nicole Sayegh Succar.
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"2022 US Sanctions and Export Controls Outlook," Association of Certified Sanctions Specialists, LLC Government Relations Taskforce Webinar, 2022.
(January 20, 2022).
Speaker: Nicole Sayegh Succar.
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"AML & OFAC Compliance for the Insurance Industry," ACI Webinar, 2022.
(January 19, 2022).
Speakers: Nicole Sayegh Succar.
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"ACAMS New York Chapter end of year round up on Current Events and Hot Topics in Sanctions," ACAMS Webinar
(November 9, 2021).
Speakers: Nicole Sayegh Succar
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"Whistleblowing Under the Anti-Money Laundering Act of 2020," An FBA Qui Tam Section Zoom Roundtable
(September 27, 2021).
Speakers: Carlton Greene, Nicole Sayegh Succar.
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"US Sanctions Policy-What’s Happened, and What Can We Expect from the Biden Administration?" ACAMS New York Chapter Webinar
(May 13, 2021).
Speaker: Nicole Sayegh Succar.
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"The 50% Rule, Indirect Sanctions Exposure & Risk Screening: Keeping up with Regulatory Expectations and Industry Best Practices," Kharon & KPMG Webinar
(May 6, 2021).
Speaker: Nicole Sayegh Succar.
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"International Trade in 2021: What’s Ahead," Crowell & Moring Webinar
(February 17, 2021).
Presenters: Vassilis Akritidis, Caroline E. Brown, Michelle J. Linderman, Joshua Pond, Nicole Janigian Simonian, David R. Stepp, Robert Clifton Burns, Carina C. Federico, Jackson C. Pai, Nicole Sayegh Succar, Michael Bowen, Chandler S. Leonard, Brian McGrath, Nimrah Najeeb, and Joshua Boswell.
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"Deep Dive into Venezuela Sanctions," ACAMS New York Chapter Webinar
(July 23, 2020).
Panelist: Nicole Sayegh Succar.
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"Emerging Issues in Sanctions, AML and Everything in Between in the Time of COVID-19: 2020 AML & Sanctions Risk Considerations for Digital Assets Companies," Crowell & Moring Webinar
(May 19, 2020).
Presenters: Caroline E. Brown, Michelle Gitlitz, Carlton Greene, Michelle J. Linderman, David (Dj) Wolff, Nicole Sayegh Succar, and Erik Woodhouse.
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"Critical Issues in the Cannabis Space," Crowell & Moring Webinar
(April 23, 2020).
Presenters: Caroline E. Brown, Anne Elise Herold Li, Eric Su, and Nicole Sayegh Succar.
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"COVID-19: 'Virtual' Sanctions Compliance: Managing Your Team and Getting Your Regulatory Updates While Remote," Crowell & Moring Webinar
(April 2, 2020).
Presenters: Caroline E. Brown, Michelle J. Linderman, David (Dj) Wolff, and Nicole Sayegh Succar.
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"OFAC Compliance Expectations", American Conference Institute, Advanced Forum on Economic Sanctions, May 2019
(May 2, 2019).
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"The Intersection Between Trade and Sanctions in Sanctions Regions Globally and the Risks for the U.S. Banks and Exporters", American Conference Institute, New York Forum on Economic Sanctions, December 2017
(December 6, 2017).
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"Demystifying Facilitation: Test Your Knowledge with Practical Scenarios of What is Permitted", American Conference Institute, Advanced Forum on Economic Sanctions, April 2016
(April 27, 2016).
Publications
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"Sanctions/Export Highlights [As of May 6, 2022]" Crowell & Moring’s International Trade Law Blog
(May 6, 2022).
Authors: Jeffrey L. Snyder, Carlton Greene, Michelle Linderman, Caroline Brown, Nicole Succar, Anand Sithian, Brian McGrath, Laurel Saito, and Rachel Schumacher.
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"Russia Sanctions/Export Highlights [As of March 10, 2022]" Crowell & Moring’s International Trade Law
(March 12, 2022).
Authors: Jeffrey L. Snyder, Carlton Greene, David (Dj) Wolff, Michelle J. Linderman, Nicole Sayegh Succar, Anand Sithian, Brian McGrath, Laurel Saito and Rachel Schumacher.
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"FinCEN and CFTC Announce $100 Million in Regulatory Settlements With Foreign Cryptocurrency Exchange for BSA Violations and Failures to Register," The Banking Law Journal
(December 6, 2021).
Authors: Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar, Anand Sithian, and Christopher Murphy.
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"Office of Foreign Assets Control (OFAC) Issues License For the U.S. Government and U.S. Government Contractors for Humanitarian Assistance in Afghanistan," Crowell & Moring’s International Trade Law
(September 22, 2021).
Authors: Jeffrey L. Snyder, Frances P. Hadfield, Anand Sithian, Nicole Sayegh Succar and Martín Yerovi.
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"Agency Issues First National Priorities for Anti-Money Laundering and Counter-Terrorist Financing, Completes Assessment on Potential No-Action Letter Process, Provides 180-Day Update on AML Act Implementation, and Appoints First-Ever Chief Digital Currency Advisor," Crowell & Moring’s International Trade Law
(July 15, 2021).
Authors: Caroline E. Brown, Kelly T. Currie, Michelle Ann Gitlitz, Carlton Greene, Rebecca Monck Ricigliano, Anand Sithian and Nicole Sayegh Succar.
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"Recent FinCEN Advisories on Medical and Consumer Fraud Scams Related to the COVID-19 Pandemic," Crowell & Moring’s International Trade Law
(July 29, 2020).
Authors: Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar and Alex Rosen.
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"Sanctions Order May Accelerate Decline In US-ICC Relations," Law360
(June 22, 2020).
Authors: Caroline E. Brown, Erik Woodhouse, Brian McGrath, Carlton Greene, David Wolff, and Nicole Sayegh Succar.
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"How FinCEN's New Global Investigation Division Changes The Department Enforcement Landscape," Westlaw Journal White-Collar Crime
(October 25, 2019).
Authors: Carlton Greene, Rebecca Monck Ricigliano, Nicole Sayegh Succar, and Nimi Haim Aviad.
Client Alerts & Newsletters
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"Treasury Sanctions Tornado Cash and Turns Up Heat on Mixers,"
International Trade Bulletin
(August 17, 2022).
Contacts: Carlton Greene, Caroline E. Brown, Anand Sithian, Nicole Sayegh Succar, Jackie Schaeffer
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"New Law Gives NYDFS Authority to Make Virtual Currency Business Activities in New York More Expensive,"
Privacy Law Alert
(May 11, 2022).
Contacts: Garylene (Gage) Javier, CIPP/US, Anand Sithian, Carlton Greene, Caroline E. Brown, Kelly T. Currie, Nicole Sayegh Succar
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"U.S., EU and UK Escalate Belarus Sanctions,"
International Trade Bulletin
(December 15, 2021).
Contacts: Carlton Greene, Michelle J. Linderman, Nicole Sayegh Succar, Anand Sithian, David (Dj) Wolff, Caroline E. Brown
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"Treasury Agencies Issue Virtual Currency Sanctions Compliance Guidance and Ransomware Trends Statistics,"
International Trade Bulletin
(November 15, 2021).
Contacts: Caroline E. Brown, Carlton Greene, Sarah Bartle, Anand Sithian, Nicole Sayegh Succar
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"FinCEN and CFTC Announce $100 Million in Regulatory Settlements With Foreign Cryptocurrency Exchange for BSA Violations and Failures to Register,"
Financial Services Alert
(August 25, 2021).
Contacts: Carlton Greene, Caroline E. Brown, Anand Sithian, Nicole Sayegh Succar, Chris Murphy
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"FinCEN Issues Major Anti-Money Laundering Act Announcements and Appoints New Chief Digital Currency Advisor,"
Financial Services Alert
(July 14, 2021).
Contacts: Caroline E. Brown, Kelly T. Currie, Carlton Greene, Rebecca Monck Ricigliano, Anand Sithian, Nicole Sayegh Succar
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"FinCEN Seeks Comment on Beneficial Ownership Reporting Requirements,"
Administrative Law Alert
(April 16, 2021).
Contacts: Caroline E. Brown, Carlton Greene, Rebecca Monck Ricigliano, Laura Schwartz, Nicole Sayegh Succar, Allison Skager
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"President Biden Imposes Additional Sanctions on Russia,"
International Trade Bulletin
(April 16, 2021).
Contacts: David (Dj) Wolff, Carlton Greene, Caroline E. Brown, Robert Clifton Burns, Nicole Sayegh Succar, Laurel Saito
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"OFAC's First Enforcement Actions Against Digital Currency Service Providers,"
Administrative Law Alert
(March 8, 2021).
Contacts: Caroline E. Brown, Carlton Greene, David (Dj) Wolff, Nicole Sayegh Succar, Laurel Saito
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"Congress Passes the Anti-Money Laundering Act of 2020, Significant Changes to the Bank Secrecy Act Ahead,"
International Trade Bulletin
(January 19, 2021).
Contacts: Carlton Greene, Caroline E. Brown, Nimrod Haim Aviad, Kelly T. Currie, Rebecca Monck Ricigliano, Nicole Sayegh Succar
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"OFAC Targets Iran’s Financial Sector and Designates Additional Iranian Banks,"
International Trade Bulletin
(October 28, 2020).
Contacts: Caroline E. Brown, Carlton Greene, Jeffrey L. Snyder, David (Dj) Wolff, Nicole Sayegh Succar, Chandler S. Leonard
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"FinCEN Issues Final Rule Establishing Anti-Money Laundering Requirements for State-Regulated Banks,"
International Trade Bulletin
(September 28, 2020).
Contacts: Carlton Greene, Caroline E. Brown, Nicole Sayegh Succar
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"FinCEN Issues ANPRM Seeking Comment on Requirement for an "Effective and Reasonably Designed" AML Program,"
International Trade Bulletin
(September 24, 2020).
Contacts: Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar
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"FinCEN Issues New Guidance for Complying with the CDD Rule,"
International Trade Bulletin
(August 18, 2020).
Contacts: Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar
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"Creation of a New Hong Kong-Related Sanctions Program,"
(July 17, 2020).
Contacts: Caroline E. Brown, Carlton Greene, David (Dj) Wolff, Nicole Sayegh Succar
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"FinCEN Provides Additional Guidance for Financial Institutions on Hemp-Related Businesses,"
International Trade Bulletin
(July 10, 2020).
Contacts: Caroline E. Brown, Carlton Greene, John Fuson, Nicole Sayegh Succar, Tyler Brown
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"NYDFS and OCC Announce Major Overhauls Important for Virtual Currency Businesses,"
International Trade Bulletin
(July 8, 2020).
Contacts: Carlton Greene, Nicole Sayegh Succar
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"Iran Triggers Dispute Resolution Mechanism Under JCPOA,"
International Trade Bulletin
(July 8, 2020).
Contacts: Michelle J. Linderman, David (Dj) Wolff, Nicole Sayegh Succar
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"U.S. Government Issues First Designations under the Caesar Act as Part of Larger Set of Designations Targeting the Syrian Government,"
International Trade Bulletin
(June 25, 2020).
Contacts: Caroline E. Brown, Carlton Greene, David (Dj) Wolff, Nicole Sayegh Succar, Tyler Brown
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"President Issues Executive Order Authorizing Sanctions on Certain Persons Associated with the International Criminal Court,"
International Trade Bulletin
(June 17, 2020).
Contacts: Caroline E. Brown, Carlton Greene, David (Dj) Wolff, Nicole Sayegh Succar
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"FinCEN’s Suspicious Activity Report Renewal Notice Seeks Public Comment on SAR Burden Estimates,"
International Trade Bulletin
(June 1, 2020).
Contacts: Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar
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"FinCEN Director Identifies Virtual Currency Compliance Risks and COVID-19 Related Issues at Consensus 2020 Conference,"
White Collar Alert
(May 20, 2020).
Contacts: Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar
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"New U.S. Sanctions Advisory for the Maritime Industry,"
International Trade Bulletin
(May 15, 2020).
Contacts: David (Dj) Wolff, Michelle J. Linderman, Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar, Nimrah Najeeb
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"Industrial Bank of Korea Agrees to a Deferred Prosecution Agreement and $86 Million in Penalties for Violations of the Bank Secrecy Act That Allowed Evasion of Sanctions on Iran,"
International Trade Bulletin
(May 13, 2020).
Contacts: Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar
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"COVID-19: The Latin America Perspective (Special Edition) – Venezuela,"
International Dispute Resolution Alert
(May 4, 2020).
Contacts: Ian A. Laird, Anne Elise Herold Li, John L. Murino, David (Dj) Wolff, Eduardo Mathison, Nicole Sayegh Succar, Karla I. Arias, Dr. sc. nat.
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"OFAC Issues Fact Sheet Regarding Humanitarian Trade Involving Sanctioned Countries and Provides COVID-19 Guidance,"
International Trade Bulletin
(April 24, 2020).
Contacts: Caroline E. Brown, Carlton Greene, Jeffrey L. Snyder, David (Dj) Wolff, Robert Clifton Burns, Nimrah Najeeb, Nicole Sayegh Succar
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"Iran Petroleum and Petrochemical Designations,"
International Trade Bulletin
(March 23, 2020).
Contacts: Nicole Sayegh Succar, Carlton Greene, Caroline E. Brown, David (Dj) Wolff, Michelle J. Linderman
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"Escalating Tensions in the Middle East: U.S. and EU Sanctions Developments on Iran,"
International Trade Bulletin
(January 15, 2020).
Contacts: Carlton Greene, Michelle J. Linderman, Jeffrey L. Snyder, David (Dj) Wolff, Nimrah Najeeb, Nicole Sayegh Succar
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"The Month in International Trade – December 2019,"
International Trade Bulletin
(January 13, 2020).
Contacts: Jeffrey L. Snyder, Edward Goetz, Carlton Greene, Michelle J. Linderman, David (Dj) Wolff, Nicole Sayegh Succar, Adelicia R. Cliffe, Maria Alejandra (Jana) del-Cerro, Nimrah Najeeb, Evan Y. Chuck, Walter (Sam) Boone
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"District Court Overturns OFAC’s $2 Million Fine Against Exxon Mobil,"
(January 7, 2020).
Contacts: Carlton Greene, Michelle J. Linderman, Jeffrey L. Snyder, David (Dj) Wolff, Nicole Sayegh Succar
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"Congress Passes New Russia and Venezuela Sanctions and Advances New Russia & Turkey Sanctions,"
International Trade Bulletin
(December 27, 2019).
Contacts: David (Dj) Wolff, Carlton Greene, Jeffrey L. Snyder, Adelicia R. Cliffe, Robert Clifton Burns, Nicole Sayegh Succar, Maria Alejandra (Jana) del-Cerro, Nimrah Najeeb
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"The Month in International Trade – October 2019,"
International Trade Bulletin
(November 8, 2019).
Contacts: Jeffrey L. Snyder, Edward Goetz, Carlton Greene, Nicole Sayegh Succar, Robert Holleyman, Walter (Sam) Boone
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"FinCEN Identifies Iran as Money Laundering Threat While OFAC Announces New Mechanism to Facilitate Humanitarian Assistance There,"
International Trade Bulletin
(November 5, 2019).
Contacts: Carlton Greene, Jeffrey L. Snyder, Nicole Sayegh Succar
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"The Month in International Trade – September 2019,"
International Trade Bulletin
(October 15, 2019).
Contacts: John B. Brew, Daniel Cannistra, Adelicia R. Cliffe, Alan W. H. Gourley, Robert Holleyman, Robert L. LaFrankie, Michelle J. Linderman, Jeffrey L. Snyder, David (Dj) Wolff, Aaron Marx, Nicole Sayegh Succar, Walter (Sam) Boone, Ru Xiao-Graham
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"New Sanctions Imposed on Elements in the Turkish Government,"
International Trade Bulletin
(October 15, 2019).
Contacts: David (Dj) Wolff, Carlton Greene, Alan W. H. Gourley, Nicole Sayegh Succar, Maria Alejandra (Jana) del-Cerro
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"Treasury Sanctions Iran’s Central Bank, Again,"
International Trade Bulletin
(September 27, 2019).
Contacts: Nicole Sayegh Succar, David (Dj) Wolff, Jeffrey L. Snyder
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"OFAC Limits Cuba “U-Turn” Payments and Remittances,"
International Trade Bulletin
(September 13, 2019).
Contacts: Carlton Greene, David (Dj) Wolff, Nicole Sayegh Succar
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"The Month in International Trade – August 2019,"
International Trade Bulletin
(September 6, 2019).
Contacts: John B. Brew, Daniel Cannistra, Maria Alejandra (Jana) del-Cerro, Carlton Greene, Robert Holleyman, Robert L. LaFrankie, Jeffrey L. Snyder, David (Dj) Wolff, Aaron Marx, Nicole Sayegh Succar, Walter (Sam) Boone, Edward Goetz, Ru Xiao-Graham
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"FinCEN Announces New Global Investigations Division and New Leader for Liaison Division,"
International Trade Bulletin
(September 5, 2019).
Contacts: Carlton Greene, Rebecca Monck Ricigliano, Nicole Sayegh Succar
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"United States Ramps Up Sanctions Pressure on Russia and Venezuela,"
International Trade Bulletin
(August 13, 2019).
Contacts: David (Dj) Wolff, Carlton Greene, Nicole Sayegh Succar, Maria Alejandra (Jana) del-Cerro, Nimrah Najeeb
Press Coverage