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Experience
Internal Investigations
- Conducted an internal investigation on behalf of a multinational financial institution relating to anti-corruption and internal controls issues arising at a Latin American affiliate.*
- Conducted internal investigation and provided advice to global organization with regard to voluntary disclosures to U.S. enforcement authorities in relation to corruption allegations involving Caribbean customs brokers.*
Government and Regulatory Investigations and Enforcement
- Represented major manufacturing client in Oregon in investigating allegations regarding the company’s third-party payment practices. The matter was resolved in October 2023 with a nonprosecution agreement. The company admitted to aiding and abetting an unlicensed money transmitting business in violation of 18 U.S.C. § 1960 relating to the company’s acceptance of payments for products sold to two Nigerian distributors through a Nigeria-based black market currency exchange network linked to a trade-based money laundering scheme in Nigeria. The resolution required the company to forfeit approximately $1.7 million but did not impose any penalty or monitorship requirements on the company.
- Secured urgent Office of Foreign Assets Control (OFAC) license in a matter of weeks for well-known global transportation manufacturing company. Addressed full production stop due to inadvertent inclusion of Cuban origin components, working closely with Perkins Coie’s strategic communications group to ensure appropriate Congressional and White House attention to critical infrastructure issues raised by the production stop while awaiting OFAC licensing.
- Obtained one of OFAC’s first-ever “assurances letters” on behalf of African bank seeking to satisfy a debt with property belonging to a former loan recipient who had been sanctioned for financing Hezbollah. Working with OFAC, the bank was able to seize property and the firm was able to achieve delisting of a sanctioned vessel so the bank could sell the vessel to recoup its debt.
- Advised offshore trustee companies in U.S. enforcement proceedings, document production, and related litigation regarding allegations of securities and tax fraud involving multiple regulators across several jurisdictions.*
- Represented multinational, publicly traded financial institution in cross-border investigation and enforcement action relating to allegations of corruption and money laundering involving conduct in the United States, China, and Mexico.*
- Advised international organization on response to subpoena received from U.S. enforcement agency in relation to multinational fraud scheme.*
- Represented multiple global companies in implementing compliance and reporting commitments under Deferred Prosecution Agreements with the DOJ.*
- Advised financial services client in OFAC inquiry relating to transaction by non-U.S. portfolio company with counterparty alleged to be a front for a sanctioned Iranian entity.*
- Represented federal criminal defendant in connection with fraud charges relating to an international investment scheme through the pro bono counsel program with the Office of the Federal Defender for the Eastern District of Virginia, including successfully briefing and arguing during the sentencing hearing for a significant variance from the applicable federal sentencing guidelines.*
Compliance Advising
- Provide regular and real-time trading advice to financial services clients regarding application of emerging sanctions to securities and bond transactions, particularly with respect to Russian and Venezuelan sanctions.*
- Submission of license application to OFAC for foreign financial institution to collect outstanding loan from a customer designated as a Specially Designated National & Blocked Person.*
- Provide ongoing advice to various multilateral development banks in relation to governance issues and the development of compliance procedures to address a variety of risks facing international organizations.*
- Conducted global risk assessments on behalf of the boards of directors for multiple publicly traded companies and proposed compliance enhancements to mitigate identified risks.*
- Assist clients in design and enhancement of business ethics and compliance programs in preparation of IPO.
- Developed comprehensive compliance program in relation to U.S. anti-corruption, economic sanctions, and anti-money laundering laws and regulations for well-known U.S. company expanding into foreign markets.*
- Conducted due diligence and provided advice on integration for global oil and gas company in relation to acquisition of U.K. subsidiary with global sales, including in many relatively high-risk jurisdictions.*
- Conducted third-party due diligence and advised on transactional safeguards for real estate investment firm in relation to foreign partners and consultants in various Eastern European jurisdictions.*
- Advised multiple investment management firms in relation to anti-corruption, economic sanctions, and anti-money laundering risks in complex cross-border transactions, including a lending deal with a Latin American pharmaceutical distributor and an option and joint venture agreement involving Argentinian mining concessions.*
- Provide regular pro bono advice to leading non-governmental organization (NGO) in relation to advocacy to the U.S. Departments of State and Treasury supporting application of sanctions under the Global Magnitsky Act.*
*Prior experience
