Adam S. Kaufmann

New York Limited Liability Companies will be subject to beneficial ownership reporting obligations pursuant to the New York LLC Transparency Act (NYLLCTA) beginning in 2026. This article discusses the requirements and potential penalties for failure to comply.

On November 24, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed a penalty of $4,677,552 on an individual in the real estate sector for knowingly renovating and selling property in Atlanta owned by a blocked individual. The investor, “U.S. Person-1,” not only violated OFAC’s Russia sanctions program, but failed to comply with an OFAC subpoena and violated the terms of an OFAC cease-and-desist letter.

On November 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions on a global network of individuals, entities, ships, and aircraft for their involvement with the Iranian regime.  The alleged network was sanctioned pursuant to OFAC’s counterterrorism authority, as set forth in Executive Order (E.O.) 13224, as amended and pursuant to the Iranian Sanctions regime, E.O. 13846 and 13902.

In an article published in the Fall edition of the International Academy of Financial Crime Litigators Bulletin, Adam Kaufmann and Eric Lewis examine new guidance from the Department of Justice on FCPA enforcement. 

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed former Paraguayan President Horacio Manuel Cartes Jara and several affiliated companies from its Specially Designated Nationals (SDN) list, reversing measures that had been in place for nearly three years under the Global Magnitsky Human Rights Accountability Act.

Cryptocurrency exchange ShapeShift AG agreed to a settlement of $750,000 with the U.S. Office of Foreign Assets Control for apparent violations of US sanctions regulations relating to Cuba, Sudan, Iran and Syria.

On October 9, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sweeping designations of almost 100 vessels, a refinery, an oil terminal and shell companies all alleged to support Iran’s illicit oil trade.  Acting pursuant to Executive Orders 13902 (targeting Iran’s petrochemical sector) and 13846 (reimposing Iranian sanctions by President Trump in his first term) this action reflects the United States’ ongoing and broad efforts to target Iran’s oil exports and choke off the revenues they bring to the regime. 

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two Iranian nationals and more than a dozen UAE and Hong Kong-based individuals and entities for coordinating transfers of funds to already-designated Iranian entities.

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) re-designated the cryptocurrency exchange Garantex Europe OU. OFAC alleged that Garantex directly facilitated cybercriminals by processing over $100 million in transactions linked to illicit activities since 2019.

LBKM partner Adam Kaufmann will speak at the third edition of the Procopio International Litigation and Arbitration Retreat, a key forum where litigators from the United States and Mexico will come together to analyze the legal challenges impacting both jurisdictions.

The Office of Foreign Assets Control of the U.S. Treasury Department announced a settlement and civil monetary penalty of USD 1,454,145 with Harman International Industries, Inc. arising from violations of OFAC sanctions on Iran.

The United States has intensified its efforts to crack down on sanctions evasion, placing particular scrutiny on the financial and commercial activities flowing through the Gulf region—especially the United Arab Emirates. Whether the focus of US foreign policy is on disrupting Russia’s war financing efforts or confronting Iran’s shadow banking network, the UAE remains a consistent “country of focus” for the US Treasury Department.

The U.S. government is laser-focused on illicit fentanyl and synthetic opioid trafficking and has shifted its approach from targeting narcotics operators themselves to focusing on their financial and commercial infrastructure: banks, brokerage houses, trade intermediaries, corporations and logistics firms. There is a clear political and enforcement intent to “make examples” of institutions—regardless of size or degree of complicity—to establish deterrence, show resolve, and build domestic political capital.

President Trump has cracked down on terror support networks in Yemen and Iran, but he has also extended hope for development in war-torn Syria.

Adam Kaufmann will join experts from the US, UK, Europe, Latin America, and Asia to debate and discuss the growth of disputes in key offshore jurisdictions.

The Office of Foreign Assets Control (OFAC) of the U.S. Treasury Department and the U.S. State Department announced sanctions against the leader of Sudan’s Rapid Support Forces (RSF) and seven UAE trading companies used by the RSF to acquire weapons and engage in banking transactions in violation of U.S. sanctions.

On December 18, 2024, the U.S. State Department announced sanctions against three Pakistani companies and a government-owned entity pursuant to Executive Order 13382, "Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters," and the Weapons of Mass Destruction Trade Control Regulations (found at 31 C.F.R. 539 et seq.).

A publicly-traded global transportation and logistics company agreed to pay $257,690 to settle an OFAC investigation that revealed 82 violations of US sanctions against Iran and Cuba by five of the company’s non-US subsidiaries.
The case illustrates the risk of failing to conduct adequate sanctions screening, as well as the advantages of self-reporting and cooperating with OFAC.

Adam Kaufmann will be speaking at a panel on private prosecutions after the Post Office Horizon scandal at the FIRE "Summer School" asset recovery event in Cambridge.

Adam will discuss victims' remedies in the US: 28 U.S.C. § 1782, TRO’s, and whistleblower actions.

Adam Kaufmann served as a panelist for this CLE on federal and local enforcement trends in the construction industry.

Adam Kaufmann co-chaired the panel "Covid-19 fraud: law enforcement and where we are now."

The Manhattan District Attorney’s investigation has nothing to do with federal law, public acts, or violations involving the political or electoral process. Moreover, as possible charges brought by a sovereign state, they cannot be pardoned by an outgoing President.

In the dying days of his administration, President Trump has moved to smash the civil service.  Through Executive Order 13957 (“EO 13957” or the “EO”), the President aims to carve out an entire new class of civil servants, sheering them from long-standing federal protections designed to create a professional, apolitical federal workforce.  Lewis Baach Kaufmann Middlemiss is investigating the scope of the Executive Order and possible remedies available to affected civil servants.

This year has seen a push for reform of Section 230 of the Communications Decency Act from both sides of the aisle. While the parties’ positions on what and how regulation should change differ greatly, they agree that Section 230 is overly broad and has allowed platform providers to amass an undesirable amount of control over the content available on the internet.

The Second Circuit held that 28 U.S.C. § 1782(a) cannot be used to support petitions for discovery for use in private foreign commercial arbitrations, settling an issue that has lingered unresolved in the circuit since 2004. The new decision, In re Guo, puts the Second Circuit squarely at odds with recent decisions issued by other circuit courts, raising the possibility that the Supreme Court will take up the issue next session to resolve the split. While Guo does not impact the ability of parties to foreign public arbitrations and litigations to take § 1782(a) discovery, for now at least, parties to private foreign arbitrations may have to look to more favorable circuits outside New York for relief.

There is a popular misconception that asset forfeiture is limited to the luxury cars, private jets and speedboats of drug dealers, but many well-meaning businesses and individuals are finding themselves with their assets seized under statutes that provide U.S. authorities extremely broad powers. And these seizures often occur without any warning to, or even accusation against, the owner of the assets. Once seized it can take years to obtain recovery of perfectly legal assets. In these uncertain times, as many well-meaning people seek the relative safety of the U.S. banking system, individuals and companies in many countries may innocently use money-transfer systems that exponentially increase the risk of having their assets seized. Why does this happen and how can it be avoided?

Adam Kaufmann moderated a panel at the inaugural OffshoreAlert Conference Latin America. The panel presented the Brazilian perspective on corruption enforcement, international cooperation, and asset recovery from both the prosecution and defense perspectives.

Adam Kaufmann delivered the keynote speech at the 15th International Arbitration Conference in Rio de Janeiro.

Adam Kaufmann delivered the keynote presentation at the Brazilian Center of Mediation and Arbitration (CBMA)'s Third International Conference.

Global Investigations Review has named Lewis Baach Kaufmann Middlemiss PLLC to its 2025 "GIR 100" list, which ranks the top law firms handling complex, cross-border investigations globally. This is the second year in a row that LBKM has made the list.

Much has been written about sweeping changes in Foreign Corrupt Practices Act (FCPA) enforcement under the Trump Department of Justice (DOJ).  An executive order signed by Mr. Trump when he took office commanded a pause in all FCPA cases, and subsequent policy memoranda and statements by DOJ officials signaled substantial changes in enforcement standards and prosecutorial focus.  A recent case filed by DOJ shows that FCPA indictments are still on the table, at least in some cases.

The trial of former Brazilian President Jair Bolsonaro, accused of a failed coup attempt following his defeat in the 2022 election, is set to end Friday, September 12, 2025. With a conviction widely anticipated and calls from Bolsonaro allies for expanded U.S. action, Brazil is bracing for potential new sanctions targeting individuals and institutions connected to the case.

Lewis Baach Kaufmann Middlemiss has been recognized for the second year in Chambers annual Latin America Guide for its Corporate Crime and Investigations practice area. Firm partners Adam Kaufmann and Cristián Francos also ranked for the first time as practitioners for the sector, demonstrating LBKM’s deepening strength and expertise in handling key issues impacting clients from the region.

Lewis Baach Kaufmann Middlemiss PLLC is once again ranked as a leading firm worldwide for Asset Tracing & Recovery in the 2025 edition of Chambers and Partners’ Professional Advisers: Litigation Support. Chambers noted the firm’s “particularly strong networks in Latin America, the Middle East and the UK.”

Chambers has again noted Lewis Baach Kaufmann Middlemiss PLLC (LBKM) for its expertise in Latin America.

The 2025 Chambers Global guide ranks the firm among the top international counsel for corporate crime and investigation matters arising out of Latin America. LBKM is the only boutique firm to be included in this elite list.

The expropriation exception to the Foreign Sovereign Immunities Act, or FSIA, permits victims of international war crimes to recover property taken by a sovereign nation in violation of international law when there is a commercial nexus to the U.S. But what happens when the property, unlawfully taken decades earlier, has long since been liquidated and cannot be traced to the present day?

LBKM partner Adam Kaufmann discusses likely enforcement priorities for the incoming US presidential administration.

Global Investigations Review has ranked LBKM as one of the world’s leading firms for cross-border investigations.

LBKM is pleased to announce that Adam Kaufmann, John Moscow, and Solomon Shinerock have been named to the 2024 New York Super Lawyers list.

The Engel List was designed as a critical foreign policy tool to identify and target individuals believed to be involved in corruption and actions undermining democratic institutions in Central America. While the List serves an important role in identifying the individuals responsible for corrupt practices in Central America, like many U.S. “lists,” it presents significant challenges from a due process perspective.

Adam Kaufmann is featured by The International Academy of Financial Crime Litigators as "Fellow of the Month." In this Q&A, Adam discusses a figure who inspires him, recommends best practices in a crisis situation, and gives advice to future litigators.

Lewis Baach Kaufmann Middlemiss made its debut this year in Chambers’ annual Latin America Guide, ranking as a leading international firm in the Corporate Crime & Investigations practice area.

LBKM is the only boutique firm to be so ranked.

The International Academy of Financial Crime Litigators has welcomed Adam Kaufmann as a new Fellow. 

Eric Lewis, A. Katherine Toomey, Adam Kaufmann, and John Moscow were recognized for their market-leading expertise in the tracing and recovery of lost, misappropriated or stolen assets.

LBKM is once again ranked as a leading firm worldwide for Asset Tracing & Recovery in the 2024 edition of Chambers and Partners Litigation Support. Chambers noted the firm’s “particularly strong networks in Latin America, the Middle East and the UK,” and clients described the firm as “extremely responsive and on the ball.”

Adam Kaufmann appeared on NBC News to discuss the verdict in Donald Trump's criminal trial.

As opening arguments were underway in Donald Trump's criminal "hush money" trial, Adam Kaufmann spoke to Anderson Cooper live on CNN.

Reuters quoted Adam Kaufmann on the possibility of Donald Trump testifying in his criminal trial. 

Adam Kaufmann was quoted in CBS News on the potential repercussions for Donald Trump if the former president fails to pay his $464 million civil fraud judgment.

Adam Kaufmann returned to NY1 to discuss the $454 million civil fraud judgment against Donald Trump.

With just 30 days for Trump to settle a hefty penalty exceeding $350 million following Friday's civil fraud trial ruling in New York City, attorney Adam Kaufmann emphasized the mounting pressure.

Lawyers for the longest-held prisoner in the U.S. war against terrorism have begun a new legal offensive in multiple courts aimed at securing his release from Guantánamo Bay.

Chambers Litigation Support 2023, a guide to leading litigation professionals, has again ranked Lewis Baach Kaufmann Middlemiss in its Global-Wide Asset Tracing & Recovery category.

Adam Kaufmann returned to NY1 to discuss the letter Donald Trump claims to have received informing him that he is a target of the DOJ's investigation into efforts to overturn the results of the 2020 presidential election.

Adam Kaufmann joined “Mornings On 1” to provide perspective on the Trump indictment in Florida.

Adam Kaufmann joined Dan Abrams on NewsNation to discuss the use and credibility of Michael Cohen as a witness in the Trump hush money case.

On March 2, 2023, the US government published a multi-agency notice setting forth red flags and warning of enhanced enforcement efforts related to third-party intermediary evasion of US Russia-related sanctions and export controls.  The Financial Times subsequently reported that a senior Treasury official stated that the UAE was a “country of focus” for US investigators.

Adam Kaufmann, who has served in the past as a top executive in the district attorney’s office and is now in private practice, said Pomerantz is exposing himself to “a lot of possible jeopardy from a bunch of different directions.”

Adam Kaufmann and John Moscow, both former financial crimes prosecutors, are quoted in this article on the possibility that a judge will give Allen Weisselberg more jail time than the five months promised as part of his plea deal.

OFAC, banking regulators and criminal enforcement authorities agree: there are big cases to be made in the crypto space. The latest example is OFAC’s October 2022 sanctions enforcement action against crypto-trading platform Bittrex, Inc.

A senior prosecutor who played a key role in New York’s investigations into former President Donald Trump has moved into private practice.

Solomon Shinerock, who left the Manhattan District Attorney’s Office on Sept. 30, joined litigation boutique Lewis Baach Kaufmann Middlemiss on Tuesday as a partner.

Who's Who Legal has recognized four Lewis Baach Kaufmann Middlemiss lawyers as leading asset recovery practitioners in its 2022 guide. 

Chambers Litigation Support 2022, a guide to leading litigation professionals, has ranked Lewis Baach Kaufmann Middlemiss in its Global-Wide Asset Tracing & Recovery category. 

The United States Supreme Court concluded in ZF Automotive US, Inc. v. Luxshare, Ltd. that federal district courts cannot order discovery for use in a private foreign arbitration via 18 U.S.C. § 1782—a statute that permits litigants to seek discovery in federal court for “use in a proceeding in a foreign or international tribunal.”  The unanimous decision narrows a useful discovery tool by prohibiting parties in or contemplating private, foreign arbitration from obtaining discovery through federal courts for use in that arbitration.

“Statements made in a civil deposition are admissible in a criminal proceeding against the person who made the statement. That’s why people can invoke their Fifth Amendment protections against self-incrimination at civil proceedings as well as criminal,” said Adam Kaufmann, a partner at the law firm of Lewis Baach Kaufmann Middlemiss who previously served as chief of the Manhattan DA’s investigative division.

The Manhattan District Attorney’s investigation into former President Donald Trump seems doomed, but a little-known New York law is buying time for prosecutors to build a better case against him and convince the hesitant new DA to act—or wait until he’s replaced.

Adam Kaufmann, speaking to Fox5's Teresa Priolo, said, "It's a little bit like blood in the water, I would say. There has to be something hard and objective that says: 'This is a problem.' That gives an accountancy -- or perhaps a law firm, in certain situations -- the signal they need to take some kind of adverse action."

On December 9, 2021, the Biden administration published the first-ever United States Strategy on Countering Corruption. This Strategy sets forth a “whole-of-government” approach to combating corruption in the United States and around the world. Individuals and entities should expect an increase in sanctions and scrutiny of activities that present high corruption-related risk. As such, companies and individuals should immediately review current business activities to ensure that they understand their exposure to corruption-related risk and have in place commensurate controls to deter and detect potential problems. A proactive approach to corruption risk now will provide material future benefits if the expected increase in regulatory and law enforcement scrutiny results in a corruption-related inquiry.

Adam Kaufmann joined Dan Abrams on NewsNation Now to discuss New York's ongoing investigation into the Trump Organization.

"The fact that they are having sealed proceedings is consistent with an ongoing grand jury investigation and suggests the district attorney may be considering further charges or defendants," said Adam Kaufmann, a former investigations division chief at the Manhattan District Attorney's Office who is currently a partner with the law firm Lewis Baach Kaufmann Middlemiss.

Who's Who Legal recognized four Lewis Baach Kaufmann Middlemiss lawyers as leading asset recovery practitioners for 2021. 

“This case had many flaws,” said Angerame’s lawyer Anthony Capozzolo. “The clients had their reputations tarnished in a way that simply was not fair or just.

“We are thankful for this decision, and the clients are eager to move on with their lives.”

In what defense attorneys characterized as a rare outcome for a government corruption indictment, a Manhattan judge dismissed charges that the New York Attorney General’s office brought against a former World Trade Center electric operations manager and two subcontractors.

[Judge] Wiley dismissed the full indictment based on testimony before a grand jury, which Lewis Baach Kaufmann Middlemiss partner Adam Kaufmann said is a not a common outcome for a bribery indictment filed by the AG. “Indictments don’t get tossed on grand jury minutes to begin with,” Kaufmann said. He added: “This was one of the most deeply flawed cases I have ever seen.”

Former President Donald Trump's company and its Chief Financial Officer Allen Weisselberg were indicted on 15 criminal charges Thursday for allegedly evading about $900,000 in taxes with the help of the Trump Organization and its payroll corporation. Yamiche Alcindor reports with Adam Kaufmann, former prosecutor and chief of the investigative division in the Manhattan district attorney's office.

Adam Kaufmann appeared on ABC News Prime to discuss the Trump Organization indictment and what might be next in the prosecution.

Adam Kaufmann was quoted in the Wall Street Journal on one of the assistant attorneys general working with Manhattan prosecutors on the probe into the former president.

Adam S. Kaufmann, who served as chief of the office's investigative division, said that "it really suggests they've reached a point in their investigation where the district attorney believes there's evidence of a crime. You don't empanel a special grand jury unless you think you have a viable case."

Adam Kaufmann, who served 18 years as a prosecutor in the Manhattan district attorney’s office, appeared on MSNBC's The Last Word to discuss why witnesses are granted immunity when testifying before a grand jury in New York and what to expect of the grand jury in the criminal probe of Donald Trump.

Adam Kaufmann was quoted in an analytical piece on Manhattan District Attorney Cyrus Vance’s investigation into Trump and his organization. 

Adam Kaufmann appeared on WNYC's "Trump, Inc." podcast to discuss what the Manhattan DA's investigation could mean for Trump.

Partner Adam Kaufmann was quoted in ProPublica's article on the Manhattan district attorney's criminal investigation of the Trump Organization and its focus on CFO Allen Weisselberg.

The Washington Post quoted partner Adam Kaufmann in its piece on Manhattan District Attorney Cyrus Vance's investigation into President Trump.

Four Lewis Baach Kaufmann Middlemiss professionals have been recognized as Global Leaders in Who’s Who Legal: Asset Recovery 2019. Who’s Who Legal is one of the world’s leading directories of legal practitioners.

Adam Kaufmann, Art Middlemiss and John Moscow remember "The Boss," longtime Manhattan District Attorney Robert Morgenthau.

“The new government of Tamaulipas is committed to taking all measures to stamp out corruption and return the proceeds of corruption to the people from whom they have been stolen,” Kaufmann said in a press release. “There are many ways that the United States courts can be used in a proactive way to trace and seize ill-gotten assets.”

« Au cours de l’enquête, BNP Paribas ne s’est pas révélée très coopérative, beaucoup moins que d’autres banques », se souvient le procureur en chef de la division des enquêtes financières, Adam Kaufmann. 

“All of this smells like a crime,” said Adam S. Kaufmann, a former chief of investigations for the Manhattan district attorney’s office who is now a partner at the law firm Lewis Baach Kaufmann Middlemiss. While the statute of limitations has long since lapsed, Mr. Kaufmann said the Trumps’ use of All County would have warranted investigation for defrauding tenants, tax fraud and filing false documents."

Woodsford Litigation Funding, one of the leading global third party funders, has announced a funding facility agreement with Lewis Baach which ensures the firm can offer clients an expedited, one-stop arrangement for the financing of high value litigation and arbitration.

Financial institutions should worry about the anti-money laundering (AML) issues that the UK Bribery Act (2010) gives rise to despite the law having been in effect for just over five years, lawyers said. The danger was thinking that because the law had existed since 2011, that compliance and legal staff have it figured out, they said.