Overview

For companies with global operations, navigating the complex web of US, UK, EU and UN sanctions and export compliance regimes is essential for avoiding legal exposure and reputational harm. Katten's Sanctions and Export Compliance group advises clients across the full spectrum of sanctions-related matters, from proactive compliance counsel through enforcement defense and resolution.

Global sanctions guidance that protects your business at every step

Our team includes former Assistant US Attorneys and seasoned practitioners with deep experience in economic sanctions, trade compliance and cross-border regulatory matters. We represent companies, funds and individuals before the Office of Foreign Assets Control (OFAC), the Bureau of Industry and Security (BIS), the Financial Crimes Enforcement Network (FinCEN), the Federal Reserve, the Department of Justice (DOJ), the New York Department of Financial Services (NYDFS), the New York Attorney General (NYAG), the Manhattan District Attorney (DANY), Customs and Border Protection, and UK/EU authorities including the Office of Financial Sanctions Implementation (OFSI).

Our clients depend on us to deliver comprehensive support — identifying, addressing and mitigating sanctions and export compliance risks before they become potential enforcement matters. When concerns about potential violations arise, we conduct independent internal investigations to scope the issues, develop the facts and determine the appropriate path forward. We work to achieve the best possible outcome, whether through cooperation, negotiation or litigation.

Katten's End-to-End Support

Preventive Compliance and Training

  • OFAC Sanctions and US Export Controls. Comprehensive counseling on program design and enhancement, risk assessments, due diligence, screening, and contractual protections.
  • Training and Program Development. Tailored training, policy and procedure drafting, testing/monitoring, and program remediation aligned with regulator expectations.

Regulatory Filings, Licensing and Remediation

  • Licensing, Delisting and Asset Unfreezing. Applications for specific/general licenses, petitions for removal from the SDN List, and strategies to retain or transact in blocked/frozen assets across jurisdictions.
  • Voluntary Self-Disclosures and Remediation. Preparation and submission of voluntary disclosures to OFAC, BIS, and related agencies, with remediation plans and compliance upgrades.
  • CFIUS Filings and National Security Reviews. Support on CFIUS submissions, diligence, mitigation strategies, and coordination with national security stakeholders in cross-border transactions.

Investigations, Enforcement and Regulator Engagement

  • Regulatory Engagement and Investigations. Representation before OFAC, BIS, FinCEN, the Federal Reserve, DOJ, NYDFS, NYAG, DANY, Customs and Border Protection, and U.K./EU authorities (including OFSI), from information requests to multi-agency enforcement matters.
  • Enforcement Defense and Internal Investigations. Independent internal reviews of potential sanctions violations, investigation scoping, factual development, and advocacy to mitigate penalties.

Transactional and Deal Risk Management

  • Transactional and Contractual Risk Management. Sanctions diligence for deals, vendor and counterparty risk assessments, and drafting of sanctions and export‑control provisions.

Trade Controls and Global Coordination

  • BIS and Trade Controls Compliance. Advice on EAR-controlled items, Russia-related restrictions, licensing and end-use/end-user screening; responses to seizures and administrative actions.
  • Cross-Border Coordination. Integrated US, UK, EU, and UN sanctions advice on complex, multi-jurisdictional matters and transactions.

Experience

  • Financial Institutions and Investigations
  • Represented a global bank in an economic sanctions investigation involving multiple US government agencies. *
  • Led internal investigations for government-owned Latin American and European banks into potential OFAC sanctions violations. *
  • Responded to FinCEN and NY Department of Financial Services investigations concerning sanctions compliance.
  • Advised credit unions on Know Your Customer (KYC) policies and procedures related to sanctions screening.
  • Funds and Asset Managers
  • Advised US and UK hedge fund managers seeking general licenses from OFSI to manage sanctioned assets.
  • Counseled fund managers on a complex UK-Luxembourg-Swiss acquisition of previously frozen assets, including regulatory approvals and rebranding of a Swiss banking subsidiary.
  • Drafted opinion letters for hedge funds regarding investments involving entities with ties to sanctioned individuals.
  • Advised funds raising capital on Committee on Foreign Investment in the United States (CFIUS) filing requirements and responded to CFIUS information requests.
  • Energy, Mining, and Commodities
  • Provided ongoing counsel to foreign sovereign-owned and private companies in the oil, gas, metals, and mining sectors on US sanctions compliance. *
  • Conducted numerous KYC investigations for energy sector companies with worldwide distributors.
  • Advised a major trading company on compliance with US sanctions. *
  • Trade, Manufacturing and Technology
  • Represented an electronics company in a DOJ National Security Division and BIS investigation, including preparing and filing voluntary disclosure letters.
  • Counseled companies on shipping procedures, export classifications, and deemed exports to employees.
  • Advised clients on UK trade sanctions involving microchips with potential military end use and related export control restrictions.
  • Aviation and Leasing
  • Advised US aircraft leasing companies on compliance with BIS restrictions related to Russia and associated licensing and exemptions. *
  • Cryptocurrency and Emerging Industries
  • Represented a cryptocurrency firm in a Federal Bureau of Investigation (FBI) investigation concerning sanctioned customers.
  • Advised Chinese companies on risk-mitigation strategies in connection with US sanctions laws.
  • Arbitration
  • Served as an expert witness on US sanctions in an arbitration proceeding. *
  • Licensing and Delistings
  • Successfully applied to OFAC for specific licenses on behalf of foreign companies after their principal source of essential supplies was sanctioned. *
  • Successfully petitioned OFAC to remove a client from the List of Specially Designated Nationals and Blocked Persons. *
  • Obtained OFSI licensing arrangements for multiple fund clients.
  • Training and Compliance Programs
  • Drafted compliance manuals for commodities companies covering sanctions, OFAC, and anti-money laundering (AML) compliance.
  • Trained client personnel in sanctions compliance and upgraded compliance policies and materials.
  • Regularly advise companies on contractual language in corporate agreements related to OFAC, sanctions, and AML issues.
* Experience prior to Katten

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