OFAC, Sanctions & AML Compliance

As regulatory scrutiny intensifies globally, financial institutions, multinational corporations, venture capital funds, and companies with international operations face increasingly complex obligations under U.S. sanctions regimes, anti-money laundering frameworks, and Know Your Customer/Client requirements. Our attorneys provide sophisticated, practical counsel designed to protect clients operating across multiple jurisdictions — from the Americas to Europe, Asia, and beyond.

With deep expertise in U.S. Office of Foreign Assets Control (OFAC) regulations, international sanctions programs, and anti-money laundering compliance, we advise clients at every stage: from designing preventive compliance frameworks to responding to government investigations and enforcement actions.

Our OFAC & Sanctions Practice

We provide comprehensive legal and compliance support across all major U.S. and multilateral sanctions programs, including:

OFAC compliance program design, review and enhancement — SDN list screening, sanctions risk assessments, and tailored policies for financial institutions, trading companies and investors
Licensing and authorization requests before OFAC, including specific and general license applications
Voluntary self-disclosure and enforcement response — advising clients who discover potential sanctions violations and navigating resolution with U.S. regulators
Sanctions due diligence for M&A transactions, joint ventures, financing arrangements and third-party onboarding
Guidance on secondary sanctions exposure for non-U.S. entities and their U.S.-nexus transactions
Monitoring of emerging sanctions developments affecting Latin America and global markets

Anti-Money Laundering (AML) & Know Your Customer/Client (KYC)

Our AML and KYC practice covers the full spectrum of compliance obligations facing financial institutions, investment funds, fintechs, and multinational corporations:

AML program design and gap assessments calibrated to the Bank Secrecy Act (BSA), FinCEN requirements, USA PATRIOT Act, and applicable international standards (FATF recommendations)
KYC and Customer/Client Due Diligence framework design, including beneficial ownership protocols and enhanced due diligence for high-risk customers and geographies
AML compliance program audits and regulatory exam preparation
Transaction monitoring and suspicious activity reporting (SAR) policy design
AML training programs for boards, senior management, compliance teams and front-line staff — delivered in English and Spanish
Support to compliance officers and their teams in managing annual AML action plans and regulatory examinations

Latin America & High-Risk Jurisdiction Experience

Our practice is distinguished by deep regional expertise in Latin America — one of the world’s most complex compliance environments. We advise clients navigating cross-border compliance exposures arising from business in jurisdictions subject to heightened FATF scrutiny or U.S. sanctions-related enforcement focus, AML risks linked to narcotics trafficking networks, organized crime, FTOs, and cartel-related activity, and the interplay between U.S. enforcement frameworks (FCPA, OFAC, BSA) and in-country anti-money laundering and anti-corruption laws throughout Latin America.

Enhanced due diligence for Politically Exposed Persons (PEPs), state-owned entities, and government-related transactions across the region. Our bilingual (English/Spanish) capability allows us to conduct on-the-ground investigations, interviews, and document reviews, and to deliver compliance training and reporting in the language of the business.

Global Financial Institutions & Investors

We have experience advising financial institutions, private equity firms, venture capital funds and family offices on the intersection of sanctions, AML and investment activity, including OFAC and AML diligence for cross-border investments and fund formations, guidance on FinCEN’s beneficial ownership rules, compliance frameworks for Fintech companies and digital asset platforms, and AML and sanctions compliance for companies accessing capital markets across multiple exchanges.

Corporate Compliance Integration

OFAC, sanctions and AML programs do not exist in isolation. We integrate these frameworks with our clients’ broader corporate compliance architecture, including alignment of OFAC/AML controls with existing FCPA, anti-bribery and corporate governance programs, internal investigation support, board and audit committee reporting, and Deferred Prosecution Agreement (DPA) implementation support.

Representative Experience

Advised a multinational construction and engineering company through the design and implementation of a comprehensive sanctions and AML compliance program following disclosure of irregularities in connection with a major Latin American infrastructure project and related U.S. Department of Justice proceedings.
Conducted enhanced due diligence and sanctions screening for a European private equity firm evaluating investment opportunities in Latin American natural resources and infrastructure.
Designed and delivered OFAC, AML and FCPA training programs for boards, senior management and compliance teams of companies operating across Latin America, Europe and the United States.
Advised a financial institution on AML program gaps and remediation strategy in preparation for a regulatory examination, including revisions to KYC procedures, beneficial ownership protocols, and SAR reporting policies.
Supported a technology company with multi-exchange capital markets exposure in designing compliance controls responsive to AML obligations under U.S., UK and in-country regulations.

Contact

Schedule a confidential consultation on your OFAC, sanctions or AML compliance needs.