Our team provides experienced advice and representation on economic sanctions matters before the U.S. Treasury Office of Foreign Assets Control ("OFAC"), the U.S. Department of State, and other agencies.
How We Can Help
- Advise on sanctions compliance in connection with international transactions
- Handle OFAC licensing matters
- Develop and review compliance plans and procedures
- Provide expert training, represent parties in connection with subpoenas, investigations and enforcement proceedings
- Prepare voluntary disclosures
- Represent parties in connection with Specially Designated Nationals de-listing petitions
- Conduct sanctions-related due diligence in connection with corporate transactions, asset sales and loan agreements
- Guide clients with regard to sanctions clauses in transaction documents and other agreements
- Represent parties before the Department of State’s Office of Sanctions Policy and Implementation in connection with Iran “secondary sanctions” on third-country targets.
Risk Assessments
We perform strategic assessments of the risks engendered by a regulated entity’s business practices. We analyze procedures for handling new types of accounts and transactions, customer identification procedures (“CIP”), suspicious activity report (“SAR”) monitoring, and other reporting obligations, and we recommend best practices based on the latest trends and case law.
Regulatory Compliance
Blank Rome’s attorneys assist clients in meeting their regulatory and compliance obligations under the Bank Secrecy Act (“BSA”), the USA PATRIOT Act, and the economic sanctions programs administered by OFAC. We represent regulated entities, including bank and non-bank financial institutions; registered investment advisers; investment companies; broker-dealers; mutual funds; transfer agents; and dealers in precious metals, stones, and jewels. Our attorneys work closely with you to design and implement appropriate anti-money laundering programs, compliance programs, and monitoring and auditing procedures for your industry.
Members of the anti-money laundering team also provide ongoing, day-to-day training and compliance assistance. We continue to monitor the appropriate regulatory agencies to ensure that you are kept apprised of trends in the regulatory environment. We assist you in responding to informal questions or formal requests from regulators regarding anti-money laundering compliance programs or other requirements under the USA PATRIOT Act—including filing SARs, FinCEN Form 8300s, and Foreign Bank Account Reports (“FBARs”), among others.
Internal Investigations
Blank Rome’s team regularly conducts sensitive corporate internal investigations and client-regulated risk assessments. Our team also deals with government attorneys in connection with implementation of corporate compliance. The goal of these internal investigations is to develop and analyze factual and legal issues, defend clients against any potential allegations, and develop creative solutions for problems that are identified as a result of the investigative process. Blank Rome also handles the media issues that often arise from high-profile investigations.
Negotiation with Regulators
In those situations where a client becomes the focus of the regulators or an enforcement action is instituted against them, we are able to draw on our prior experience in an effort to negotiate reduce, or mitigate any proposed civil monetary penalties. Blank Rome concentrates its practice before certain regulators, such as the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”).
