Publications, Presentations & Events Archive

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.

In Ashley v. Deutsche Bank, the Second Circuit affirmed the dismissal of a complaint brought under the Justice Against Sponsors of Terrorism Act (“JASTA”) against three banks. The decision applies the JASTA aiding and abetting standard from the Supreme Court’s recent decision in Twitter v. Taamneh, 598 U.S. 471 (2023), and offers guidance in this evolving area of the law.

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.

The United States Deputy Attorney General has issued guidelines for FCPA investigations and enforcement as directed by Executive Order 14209.

In a recent enforcement action, FinCEN used Section 311 of the USA PATRIOT Act’s “special measures” to exile a “network” of Cambodia-based businesses, including a crypto brokerage, from the U.S. financial system.

Cristian Francos will be co-chairing the 27th annual transnational crime conference from May 14-16 at the Ritz-Carleton in Santiago, Chile.

Corruption often causes significant harm to businesses and individuals by undermining fair competition and depriving them of rightful opportunities. The United States’ Mandatory Victim Restitution Act (MVRA) provides a powerful legal mechanism for victims to seek restitution for their losses.

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.

Subsidiaries of the Canadian listed company Jura Energy Corporation have won an ICC arbitration against Petroleum Exploration (Private) Limited, a Pakistan-based oil & gas operator.

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.

As part of Washington Arbitration Week, Alex Bedrosyan appeared on a panel discussing whether and how to revise the New York Convention to improve efficiency and fairness in the enforcement of foreign arbitral awards.

When a three-arbitrator tribunal issues a unanimous award but one of the arbitrators is found to have had actual or apparent bias, must the award be vacated?

Fakhruddin Valika will participate in a mock case management conference following a fireside chat for young arbitration practitioners at Dubai Arbitration Week.

Cristián Francos co-moderates a panel on business crime crisis situations in a corporate environment at the International Bar Association's Annual Conference taking place in Mexico City on 15–20 September 2024.

Cristián Francos will be speaking at the 7th Marval Summit on Compliance, Anti-Corruption, and Investigations. Together with renowned speakers and colleagues, he will share experiences on the challenges, developments, and trends in this practice area. 

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.

In this panel at the 2024 Asset Recovery Americas Conference, partner Chiara Spector-Naranjo and fellow panelists will discuss what avenues are available to victims or insolvency practitioners where a defendant has no assets, be it an offshore shell company that has been asset stripped, or a fraudster whose assets have already been seized or confiscated.

LBKM is proud to sponsor this year's CenterForce Driving Diversity in Law & Leadership Summit in Washington, DC, where Managing Partner Aisha Bembry will be a panelist at a session titled "Shattering Glass Ceilings: The Unwritten Playbook for Career Success Beyond Hard Work."

The U.S. lags other countries in crypto adoption, and unfavorable policy is only one reason. Another is that the problems crypto addresses are more prevalent in other countries. Join LBKM's Carol Van Cleef and fellow panelists at this open forum to share your experience and ideas about what moves the needle on crypto adoption and usage around the world.

As part of the IBA's 26th Annual Transnational Crime Conference in Milan, Cristián Francos co-moderates a panel dissecting the intricate landscape of subsidies fraud in the aftermath of the Covid-19 pandemic.

Carol Van Cleef authored a chapter in this treatise in which industry leaders provide insightful analysis on how emerging advances in Web3, Blockchain, and Metaverse law interact within new and existing legal frameworks. Formerly published as A Practical Guide to Smart Contracts and Blockchain Law.

Cristian Francos will moderate a panel at the inaugural IBA Arbitration and Criminal Law Conference. 

Cristián Francos moderated a panel exploring the growing trend to arbitrate disputes emerging from compliance investigations related to potential criminal conduct and will discuss the varying ways national courts review and accept any arbitral decisions in this area.

Partner Tara Plochocki will be speaking on "The evolving impact of sanctions on commercial contracts" as part of London International Disputes Week.

Partner Cristián Francos will co-chair a session on trends in global sanctions enforcement at the International Bar Association's 25th Annual Transnational Crime Conference.

Cristián Francos discussed the operation of Money Service Businesses without a license, US government enforcement and prosecution, and the impact for local financial actors.

Cristián Francos is Senior Vice Chair of the IBA’s Business Crime Committee and will be co-chairing “The transfer of criminal liability in M&A” session on November 3rd.

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."

On October 19, 2021, the U.S. District Court for the District of Columbia granted Guantánamo detainee Asadullah Haroon Gul’s petition for a writ of habeas corpus, ruling that his detention is unlawful. The decision marks the first time a Guantánamo Bay detainee has won a habeas corpus petition in the last ten years.

U.S. government surveillance has repeatedly been in the news, highlighting the larger U.S. surveillance system of foreigners and the incidental gathering of Americans’ communications.  The U.S. government’s surveillance capabilities and long-standing policies have sparked concern and reaction from the European Union (“EU”), and now, in response to a European court ruling, European partners are reaching out to their U.S. counterparts asking to amend existing contracts to strengthen or install protections concerning European data.  How U.S. entities respond to such requests can determine whether their commercial relationships continue uninterrupted and potentially give them a leg up against the competition.