Sean M. Thornton
Financial Institutions Regulation and Enforcement
Sean M. Thornton is a counsel in Skadden’s Financial Institutions Regulation and Enforcement Group. He advises financial institutions and companies in other sectors with respect to the economic sanctions administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and related laws and regulations. Mr. Thornton assists clients with internal investigations, regulatory examinations, and civil and criminal enforcement proceedings, and he advises companies and their boards on developing internal controls to comply with increasingly complex economic sanctions requirements.
Mr. Thornton served as OFAC’s chief counsel from 2005 to 2012 and was responsible for legal support to all its regulatory and enforcement activities. As OFAC’s top legal officer, Mr. Thornton played a leading role in negotiating numerous settlements with entities for alleged violations of U.S. sanctions, including several landmark cases involving international financial services companies.
Mr. Thornton was instrumental in the development of the expanded legal framework for U.S. sanctions with respect to Iran, including regulations implementing OFAC’s responsibilities under the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010 (CISADA) and similar secondary sanctions. He was integrally involved in the development and implementation of sanctions against Syria and Libya as well as other major national security challenges, including the drafting and interagency negotiation of more than 20 executive orders. Mr. Thornton supervised numerous high-profile litigation matters, including the successful defense of OFAC’s authorities in relation to counterterrorism issues and the sanctions against Cuba and Iraq.
After an appellate clerkship and three years in private practice, Mr. Thornton joined the Treasury Department in 2001 as an attorney adviser in the Office of the General Counsel. He served as senior adviser to the general counsel of the Treasury Department from 2003 to 2005, when he was selected to be OFAC’s chief counsel. In 2012, Treasury Secretary Timothy F. Geithner bestowed upon Mr. Thornton the Distinguished Service Award in recognition of “extraordinary contributions to countless national security matters” during his government service.
- New York University School of Law, Center for Human Rights and Global Justice, “Smart Sanctions and the Rule of Law,” June 2012
- Practising Law Institute, “Coping With U.S. Export Controls,” December 2011 and December 2010
- U.S.-China Strategic and Economic Dialogue, September 2011
- Washington Foreign Law Society and the American Society of International Law, “U.S. Sanctions on Iran,” February 2011
- U.S. Department of Commerce, Bureau of Industry and Security, Export Control Forum, February 2011
J.D., Georgetown University Law Center, 1997 (cum laude)
A.B., Harvard College, 1994 (magna cum laude)
U.S. Department of the Treasury: Chief Counsel, Office of Foreign Assets Control (2005-2012), Senior Adviser to the General Counsel (2003-2005), Attorney Adviser, Office of the General Counsel (2001-2003)
Law Clerk, District of Columbia Court of Appeals, Hon. John M. Steadman (1997-1998)