International Economic Sanctions & OFAC Compliance

Debevoise’s market-leading sanctions compliance & enforcement practice provides expert and practical advice on trade and economic sanctions matters to a wide range of institutions as well as leading industry associations. Our attorneys draw upon extensive experience, both from the private sector and in government to manage sanctions risk and support our clients’ global business operations.

We help our clients navigate sanctions issues arising in their corporate transactions or in the course of their business, represent clients faced with regulatory inquiries or enforcement actions, and devise appropriate sanctions compliance systems and controls to guard against future enforcement risk.

If a potential sanctions issue is identified, we assist with the remediation process by deploying our investigative know how and representing clients in adversarial proceedings, ranging from contentious regulatory examinations to administrative enforcement actions to civil and criminal litigation.

Recently, Debevoise has assisted clients in:

  • reviewing, revising and implementing sanctions compliance policies and procedures (including with respect to compliance programs that need to address both U.S. and foreign requirements);
  • Performing sanctions compliance assessments (including with respect to the structuring of compliance in multinational organizations);
  • advising on structuring transactions to comply with sanctions limits;
  • performing diligence on counterparties for purposes of sanctions, anti-corruption and anti-money laundering compliance;
  • providing sanctions training, both for front-line employees and for boards of directors;
  • performing internal investigations regarding potential OFAC and other sanctions compliance issues;
  • advising both Russian and non-Russian clients on sanctions risks posed by transactions with entities in Russia;
  • responding to regulatory and law-enforcement inquiries regarding US and EU sanctions matters; and
  • representing clients in proceedings and enforcement actions instituted by the U.S. Justice Department, U.S. federal banking regulators, OFAC, the UK Office of Financial Sanctions Implementation and the New York Department of Financial Services.

The Debevoise team works collaboratively across offices around the world. We have leading lawyers who advise on sanctions, anti-corruption and related issues in our Hong Kong, London, New York, Moscow and Washington, D.C. offices. Our practice draws on the experience and expertise of members of the firm’s Banking, Financial Institutions, Litigation and White Collar & Regulatory Defense practices.

The depth of the practice means we are able to build the right teams for the job at hand. That may be anything from a lean partner-led team to focus on a specific issue for a client, to a bench of heavy-hitters for highly complex and business-critical sanctions matters.

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; and 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. The team also includes a number of former Assistant United States Attorneys, a former New York State Department of Financial Services General Counsel for Insurance, and a former senior lawyer with the Board of Governors of the Federal Reserve System.

We write and speak regularly on these topics, including as authors of the OFAC chapter of the leading treatise on requirements for non-U.S. banks doing business in the United States. 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.

We pride ourselves on finding practical solutions to sanctions problems and issues. We advise on structuring transactions to comply with sanctions restrictions, not only those coming from legal restrictions, but also those imposed by international lenders, investors and other counterparties. We are well placed to provide expert guidance on issues requiring consultation with U.S., EU and UK authorities, using, as appropriate, our knowledge of and contacts within the relevant government agencies.