Skadden represents a wide variety of U.S. and international clients in regulatory, civil and criminal matters involving U.S. and European anti-money laundering (AML) and economic sanctions laws, including those administered by the U.S. Office of Foreign Assets Control (OFAC), the U.S. Financial Crimes Enforcement Network (FinCEN) and other U.S. federal and state regulators; the European Union; Her Majesty’s Treasury; the U.K. Office of Financial Sanctions Implementation; the French Ministry of Finance; and the French General Directorate of the Treasury, among others.
Skadden advises global financial institutions, payment services providers, digital asset service providers and other multinational companies from all industries, their boards and senior officers, and individuals in all aspects of global economic sanctions and anti-money laundering compliance.
We have substantial experience helping our clients prepare for and respond to regulatory examinations, assessing the need for and drafting voluntary disclosures, and conducting internal investigations and transactional due diligence. We also defend our clients in enforcement proceedings before all major federal and state regulatory agencies, including OFAC, FinCEN, the Federal Reserve board, the U.S. Office of the Comptroller of the Currency and the New York State Department of Financial Services, as well as federal and local prosecutors, and have successfully resolved a number of multi-agency civil and criminal settlements. Additionally, we assist with various disclosure requirements for European investigative agencies, including the U.K. Office of Financial Sanctions Implementation, the U.K. Serious Fraud Office, the U.K. Financial Conduct Authority, the U.K. Prudential Regulatory Authority, the German Federal Financial Supervisory Authority and public prosecutors, the French National Financial Prosecutor’s Office (Parquet National Financier), the French Anti-Corruption Agency, the French Prudential and Resolution Control Authority, the French AMF and investigating magistrates.
We also offer substantial experience with post-enforcement remediation matters. Our attorneys frequently assist clients in developing and implementing internal compliance programs and advise on the design of remedial measures (including in-house training programs). We advise our clients in executing AML and OFAC lookbacks mandated by regulators. Additionally, our team provides legal and strategic advice to clients who engage monitors and independent consultants regarding the conduct of such reviews and in responding to findings and recommendations.
Before any such needs arise, we engage at the ground level to prevent and detect potential violations of law with our day-to-day compliance counseling. Our team has assisted hundreds of clients, including scores of the world’s largest banks, in reviewing, developing and implementing worldwide sanctions and AML compliance programs to identify and avert potential legal breaches. We design and tailor compliance programs to meet each client’s business requirements, taking into account the existing organizational and management structures, culture and global needs, as well as the expectations of regulators.