Anti-money laundering (AML) and economic sanctions are areas of tremendous complexity and constant change—areas that continuously present unique and difficult challenges to financial institutions. At the same time, numerous high-profile enforcement actions provide concrete evidence that AML and economic sanctions compliance has been—and, for the foreseeable future, will continue to be—top priorities for regulators and law enforcement, within the United States and globally.
Institutions now face the very real prospect of billion-dollar fines and criminal prosecution for lapses. In the current environment, there can be no doubt that AML and economic sanctions compliance are critical to effectively managing risk and must be a focus of the boards of directors and senior management of financial institutions.
Interdisciplinary AML and Sanctions Team
Sullivan & Cromwell is ideally positioned to assist financial institutions in navigating AML and economic sanctions program challenges. To do so effectively, it is often necessary to bring diverse skills to bear:
- deep regulatory knowledge to identify a challenge;
- investigatory skills to identify its source, scope and magnitude;
- practical experience and creativity to develop sound remedial strategies;
- the capacity to adapt and adjust in the face of changing regulatory or law enforcement expectations;
- the ability to hone in on what is important, filter out the noise, and communicate critical information to stakeholders, whether they are internal to the institution or regulatory or law enforcement authorities;
- insight into past, present, and potential future enforcement trends to maximize leverage in settlement negotiations; and
- the capacity to comprehensively assess and develop sound strategies to address the potentially severe collateral consequences of regulatory or law enforcement action.
The Economic Sanctions and Financial Crime Group includes leading practitioners with demonstrated expertise and extensive experience in each of these areas. Included in the Group are former federal prosecutors and former government officials from the New York State Banking Department (now the New York Department of Financial Services), the Board of Governors of the Federal Reserve System, the Federal Reserve Bank of New York, the U.S. Department of the Treasury’s Office of Foreign Assets Control (and Office of Terrorism and Financial Intelligence), and the New York Stock Exchange (now the Financial Industry Regulatory Authority) Enforcement Division. Together, the Group's unique interdisciplinary team—with lawyers whose practice area specialties range from supervision and regulation to investigations and litigation to mergers and acquisitions to Congressional investigations—is prepared to assist financial institutions with any AML or economic sanctions enforcement or compliance challenges they may face.
Regulatory, Enforcement and Litigation Expertise
S&C’s Economic Sanctions and Financial Crime Group practitioners have provided counsel in nearly every high-profile AML and economic sanctions-related regulatory enforcement action and law enforcement action involving a financial institution in the last decade, making it a preeminent presence in the areas of AML and economic sanctions enforcement and compliance.
S&C regularly advises clients of all sizes across various jurisdictions on Bank Secrecy Act (BSA)/AML and economic sanctions compliance and enforcement matters. This extensive experience has afforded us a deep understanding of the important issues faced by financial institutions in compliance as well as regulatory and criminal enforcement contexts.