概览

我们在跨境金融服务合规、内部调查、监察行动及争讼纠纷方面经验丰富,即使无法完全避免跨境风险,亦能够成功将其化解。在多个国家运营或跨境提供金融产品及服务的客户,往往面临相互矛盾的国内外法律和监管要求。与此同时,美国、欧洲及亚洲的金融服务监管当局愈加严格地审查多辖区运营的金融机构,不断针对该等机构推行协同调查及执法行动。随着金融交易和市场一体化趋势继续发展,潜在风险承担势必将有增无减。

执业经验

  • 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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