Anti-Money Laundering /Sanctions Compliance & Enforcement

www.debevoise.com

Debevoise’s market-leading AML / Sanctions Compliance &

Enforcement practice provides expert and practical advice on

anti-money laundering and economic sanctions matters to a wide

range of institutions—including multinational banks, securities

broker-dealers, asset managers, consumer credit and travel-related

service providers—as well as leading industry associations. Our

attorneys draw upon extensive experience (both from the private

sector and in government). We work with clients in all types of

adversarial proceedings, ranging from contentious regulatory

examinations to administrative enforcement actions to civil and

criminal litigation.

1Debevoise & Plimpton Anti-Money Laundering / Sanctions Compliance & Enforcement

Debevoise assists clients in:

• reviewing, revising and implementing BSA/AML and sanctions-related compliance policies and procedures (including with respect to compliance programs that need to address both U.S. and foreign requirements);

• performing compliance assessments (including with respect to the structuring of compliance in multinational organizations);

• providing BSA/AML and sanctions training;

• leading internal investigations regarding potential BSA/AML, OFAC and related compliance issues;

• responding to regulatory and law-enforcement inquiries regarding BSA/AML and OFAC matters; and

• defending proceedings and enforcement actions instituted by the U.S. Justice Department, U.S. federal banking regulators, OFAC, the UK Serious & Organised Crime Agency and the New York Department of Financial Services.

The Debevoise team works collaboratively across offices around the world and draws on the experience and expertise of members of the firm’s Banking, Financial Institutions, Litigation and White Collar & Regulatory Defense practices. 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; 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; and a team of former Assistant United States Attorneys. The team also includes senior lawyers with other government experience, including with the Federal Reserve Board.

In addition to our work on behalf of clients, we are thought leaders on AML and sanctions issues. We write and speak regularly on these topics, including as authors of the leading treatise on AML and OFAC requirements for non-U.S. banks doing business in the United States. Within the past year, members of the team have spoken at leading industry conferences in New York, London, Hong Kong and Singapore.

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.

2

Examples of AML/Sanctions Compliance & Enforcement Matters• Large financial institution in an

investigation conducted by the DOJ, FinCEN and federal banking regulators on money laundering charges.

• Foreign bank in responding to a subpoena (which seeks information related to the bank’s clients and accounts connected to Mossack Fonseca & Co., the Panamanian law firm at the center of the International Consortium of Investigative Journalist’s “Panama Papers” project) issued by the DOJ and the U.S. Attorney’s Office for the Southern District of New York.

• Leading U.S. bank in a series of OFAC self-disclosures and settlements.

• Leading national bank in an AML investigation by New York State and federal authorities in an investigation related to AML and fraud.

• Large multinational bank in negotiations with the NYDFS over a potential settlement relating to AML/BSA compliance.

• Multinational state-chartered bank in a NYDFS investigation into potential AML/BSA noncompliance.

• Foreign state-chartered bank in an enforcement action brought by the NYDFS, which resulted in successfully negotiating a reduction in the penalty demand.

• Leading U.S. bank in the acquisition of a financial technology firm and the integration of that firm into its AML/BSA compliance framework.

• Multiple firms to plan for and meet the forthcoming compliance obligations of the CDD Rule and NYDFS Part 504.

• Global sanctions compliance assessment and report to the board of directors of a multinational insurer on the structure and strength of its OFAC and EU sanctions compliance program.

3Debevoise & Plimpton Anti-Money Laundering / Sanctions Compliance & Enforcement

Awards and Recognitions

Ranked in the top tier in New York for Investigations. Chambers USA, 2017

Ranked in the top tier in London for Financial Crime: Corporates. Chambers UK, 2017

Recognized as a leading practice in the “Sanctions Law Firm of the Year, U.S.A.” category. WorldECR Awards, 2015 & 2016

Named as one of the top investigations practices in the world in the inaugural GIR 30.

“Debevoise & Plimpton has market-leading lawyers on the ground in the centres of world finance and market regulation, making it well equipped to take on some of the biggest white-collar cases.” Global Investigations Review, 2015

4

Key Contacts

Matthew L. BibenPartner, New York mlbiben@debevoise.com +1 212 909 6606

Helen V. CantwellPartner, New York hcantwell@debevoise.com +1 212 909 6312

Lord (Peter) Goldsmith QC, PCPartner, London phgoldsmith@debevoise.com +44 20 7786 9088

Arian M. JuneCounsel, Washington DC ajune@debevoise.com +1 202 383 8053

Satish M. KiniPartner, Washington DC smkini@debevoise.com +1 202 383 8190

Paul L. LeeOf Counsel, New York pllee@debevoise.com +1 212 909 6955

Carl MicarelliCounsel, New York cmicarelli@debevoise.com +1 212 909 6813

Michael B. MukaseyOf Counsel, New York +1 212 909 6589

David A. O’NeilPartner, Washington DC daoneil@debevoise.com +1 202 383 8040 +1 202 809 1995

5Debevoise & Plimpton Anti-Money Laundering / Sanctions Compliance & Enforcement

Alex ParkerInternational Counsel, London aparker@debevoise.com +44 20 7786 9130

Philip RohlikCounsel, Shanghai prohlik@debevoise.com +86 21 5047 1800 x 218 +86 21 5047 0788

David SarrattPartner, New York dsarratt@debevoise.com +1 212 909 6864

Karolos SeegerPartner, London kseeger@debevoise.com +44 20 7786 9042

Jane ShvetsPartner, London jshvets@debevoise.com +44 20 7786 9163

Bruce E. YannettPartner, New York beyannett@debevoise.com +1 212 909 6495

6

January 2018