Practice Areas
OFAC, Sanctions & AML Compliance
Practical counsel on U.S. sanctions, anti-money laundering and Know Your Customer obligations for financial institutions, multinationals, funds and companies operating across multiple jurisdictions.
Overview
From preventive frameworks to enforcement response
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.
With deep experience in U.S. Office of Foreign Assets Control (OFAC) regulations, international sanctions programs and AML compliance, we advise clients at every stage, from designing preventive compliance frameworks to responding to government investigations and enforcement actions.
OFAC & sanctions
Support across all major U.S. and multilateral sanctions programs
- 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, and resolution with U.S. regulators
- Sanctions due diligence for M&A transactions, joint ventures, financings 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
AML & KYC
The full spectrum of anti-money laundering obligations
- AML program design and gap assessments calibrated to the Bank Secrecy Act, FinCEN requirements, the USA PATRIOT Act and FATF recommendations
- KYC and customer due diligence frameworks, 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 for boards, senior management, compliance teams and front-line staff, in English and Spanish
- Support to compliance officers in managing annual AML action plans and regulatory examinations
Latin America
Experience in high-risk jurisdictions
Our practice has a strong focus on Latin America, one of the world’s most complex compliance environments. We advise on exposures arising from jurisdictions under heightened FATF scrutiny or U.S. sanctions enforcement focus, AML risks linked to narcotics trafficking, organized crime and foreign terrorist organizations, and how U.S. frameworks (FCPA, OFAC, BSA) interact with local laws that affect our clients, coordinating with local counsel where required.
We conduct enhanced due diligence on politically exposed persons, state-owned entities and government-related transactions, and our bilingual team carries out interviews, document reviews, training and reporting in the language of the business.
Financial institutions & investors
Sanctions and AML in investment activity
We advise financial institutions, private equity firms, venture capital funds and family offices on OFAC and AML diligence for cross-border investments and fund formations, FinCEN’s beneficial ownership rules, compliance frameworks for fintech companies and digital asset platforms, and sanctions and AML compliance for companies accessing capital markets across multiple exchanges.