WASHINGTON, D.C. (MAY 2, 2024) — Sullivan & Cromwell LLP announced the creation of its National Security Practice to provide integrated advice to clients navigating the challenges posed by the enhanced use of economic sanctions, anti-money laundering laws, the Foreign Corrupt Practices Act (FCPA), foreign investment regulations, export controls and import restrictions.
“The government is sharpening its focus on national security issues arising in a range of industries. Our lawyers have advised on nearly every high-profile sanctions and AML-related enforcement action involving the banking industry, where national security concerns have long animated government regulation and enforcement. We bring this deep understanding to our work for clients in technology, manufacturing and other industries that the government increasingly views as significant to U.S. national security,” said Sullivan & Cromwell Co-Chairs Robert J. Giuffra Jr. and Scott Miller. “We are creating our National Security Practice Group to bring together our firm’s extensive expertise to deliver integrated service to our clients.”
Recent examples of the firm’s work in this area include advising:
- Barclays Bank, BNP Paribas, Danske Bank, HSBC, ING Group, JPMorgan Chase Bank, MUFG, Standard Chartered and Wells Fargo, along with other U.S. and non-U.S. financial institutions and multinational corporations, on business-critical OFAC matters
- Barclays, Credit Agricole, Ericsson and Standard Chartered Bank in ATA/terrorism-related litigation
- Numerous companies on CFIUS aspects of acquisitions, including CNH Industrial in its agreement to acquire Hemisphere GNSS Inc.; Canadian Pacific Railway in its $31 billion acquisition of Kansas City Southern; and BHP Group Limited on the transfer of its oil and gas portfolio to Woodside Energy Group
- Numerous companies on FDI aspects of acquisitions, including Amgen in its $27.8 billion acquisition of Horizon Therapeutics; L3Harris Technologies UK in its pending $1.96 billion acquisition of Viasat’s Tactical Data Links product line; and Leonardo DRS in its merger with RADA Electronic Industries
S&C’s National Security Practice includes lawyers with senior-level experience in government, including the former head of OFAC, a former U.S. ambassador, Justice Department officials and former heads of the enforcement divisions of the SEC and CFTC. Several of our lawyers have active security clearances and others can reactivate their clearance in short notice. The team applies a global, multidisciplinary approach to advise clients conducting cross-border economic transactions as they navigate new and complex compliance issues and potential investigations and enforcement actions.
Leaders of S&C’s National Security Practice include:
- Karen Seymour, Partner in S&C’s Litigation Group and former Chief of the Criminal Division for the U.S. Attorney’s Office for the Southern District of New York
- Adam Szubin, Of Counsel in S&C’s Financial Services Group and former Acting Under Secretary of Treasury for Terrorism and Financial Intelligence and former Director of Treasury’s Office of Foreign Assets Control (OFAC)
- Sharon Cohen Levin, Co-Head; former Head of the Money Laundering and Asset Forfeiture Unit in the U.S. Attorney’s Office for the Southern District of New York
- Nicole Friedlander, Co-Head; Co-Head of S&C’s Cybersecurity Practice and former Chief of the Complex Frauds and Cybercrime Unit in the U.S. Attorney’s Office for the Southern District of New York
- Anthony Lewis, Co-Head; Co-Head of S&C’s Cybersecurity Practice and former Deputy Chief of the Terrorism and Export Crimes Section in the U.S. Attorney’s Office for the Central District of California
- Eric Kadel, Co-Head; Co-Head of S&C’s Foreign Investment and Trade Regulation and Economic Sanctions and Financial Crime Groups
- Craig Jones, Co-Head; Administrative Partner responsible for leading the compliance efforts of S&C’s London office, including regulated roles as Money Laundering Compliance Officer, Data Protection Officer and Compliance Officer for Legal Practice
- Aisling O’Shea, Co-Head of the firm’s FCPA and Anti-Corruption Practice and former trial attorney in the FCPA Unit of the Fraud Section of the U.S. Department of Justice’s Criminal Division
- Michael George DeSombre, Head of S&C’s Korea, Southeast Asia and Asia Mergers & Acquisitions practices and former United States Ambassador to the Kingdom of Thailand
- Andrew DeFilippis, Special Counsel in S&C’s Litigation Group and former senior member of the National Security and International Narcotics Unit in the U.S. Attorney’s Office for the Southern District of New York and Counselor to the Secretary of Homeland Security
- Amanda Houle, Special Counsel in S&C’s Litigation Group and former Co-Chief of the National Security & International Narcotics Unit in the U.S. Attorney’s Office for the Southern District of New York
The practice draws experience from the firm’s award-winning Financial Services, Criminal Defense & Investigations, Digital Assets, Privacy, Payments, Cybersecurity, Economic Sanctions and Financial Crime, FCPA & Anti-Corruption, Foreign Investments and Trade Regulations, Project Development & Finance and M&A practices.
Further information about S&C’s National Security Practice Group may be found here.
About Sullivan & Cromwell LLP
Sullivan & Cromwell LLP is a global law firm that advises on major domestic and cross-border M&A; significant litigation and corporate investigations; finance and corporate transactions; and complex antitrust, regulatory, tax and estate planning matters. Our firm’s hallmarks are the highest-quality independent advice and intense dedication to solving client problems. Founded in 1879, Sullivan & Cromwell has more than 900 lawyers located in offices in New York, Washington, D.C., Los Angeles, Palo Alto, London, Frankfurt, Paris, Brussels, Hong Kong, Beijing, Tokyo, Melbourne and Sydney.