Visión general

Our experience with cross-border financial services compliance issues, internal investigations, supervisory actions and contentious disputes allow us to successfully resolve, if not avoid entirely, cross-border risks. Our clients that operate in more than one country or that offer their products and services across borders face an often conflicting web of foreign and domestic legal and regulatory requirements. At the same time, financial services supervisory agencies in the United States, Europe and Asia are closely scrutinizing institutions that operate in multiple jurisdictions and increasingly pursuing coordinated investigatory and enforcement actions against them . These sources of potential exposure will only increase as the trend toward integration of financial transactions and markets continues.


  • International bank in connection with internal investigations and possible voluntary self disclosure to OFAC regarding possible violations of US sanctions laws, primarily concerning Cuba and Iran, involving wire transfers, trade finance and US origin goods.
  • Large bank client in connection with a threatened enforcement action arising out of violations of the Farm Credit Act and the Farm Credit Administration’s implementing regulations. Conducted extensive internal investigations into the bank’s criminal referral procedures and practices involving loans to affiliated entities, and advised a special committee of the board of directors on remedial steps.  Recommended improvements to the Bank’s legal hold procedures.
  • Major bank holding company and subsidiary bank in regulatory enforcement actions taken by federal authorities for loan asset quality and related issues.
  • Multinational financial services company in responding to a Congressional subpoena for transaction records and account information about its maintenance of a correspondent account for a foreign bank in connection with a Congressional investigation into US dollar denominated funds transfers through the US banking system to certain high risk countries.
  • Non-US banks in connection with actions brought by the United States government in connection with efforts to collect taxes from U.S. citizens that maintained undisclosed accounts.
  • International bank in two suits filed in US court under the Anti-Terrorism Act seeking to hold the bank liable for deaths and injuries that plaintiffs suffered in Israel during incidents of HAMAS and Hezbollah terrorism.

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