Sanctions and Export Control // National Security

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.

Lewis Baach Kaufmann Middlemiss PLLC (LBKM) is pleased to announce that Ahmed Almudallal, a former trial attorney in the U.S. Department of Justice’s National Security Division, has joined the firm as partner. With over 13 years of experience investigating and litigating complex financial and national security matters, Mr. Almudallal brings a unique blend of government insight and courtroom expertise to the firm’s global litigation and investigations practice.

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.

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.

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.

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. 

Solomon Shinerock writes in Law360 about the unintended consequences of OFAC's expansion of the Specially Designated Nationals List.

Cristián Francos was quoted in an article discussing the frameworks used in many Western countries to provide compensation to overseas victims of economic crime.

ABF Fellows are a global honorary society of attorneys, judges, law faculty, and legal scholars whose public and private careers have demonstrated outstanding dedication to the highest principles of the legal profession and to the welfare of their communities.

Who's Who Legal (WWL) has again recognized Cristián Francos as a global leader in the field of investigations. WWL highlights lawyers at the forefront of the investigations field, spanning white-collar crime, corporate compliance and regulatory enforcement.

Eric Lewis and Solomon Shinerock successfully petitioned OFAC to remove a vessel from the SDN list. The vessel was listed pursuant to Executive Order 14024, relating to the Russian sanctions program, due to a misidentification of ownership.

Carol Van Cleef was quoted in Money Laundering Bulletin on the dynamic compliance frontline of sanctions enforcement.

The National Black Lawyers is an invitation-only professional development and networking association comprised of the top African American attorneys from across the country.

In light of the severe consequences of running afoul of OFAC's directives, there has not been enough meaningful opportunity to challenge the scope and basis of OFAC's decision making, Solomon Shinerock and Annika Conrad argue in Law360.

Tom Malinowski, two-term representative for New Jersey's 7th Congressional District and former vice chair of the House Foreign Affairs Committee, is moving to an international litigation boutique to serve as senior policy consultant. 

In Turkiye Halk Bankasi A.S. v. U.S., the Supreme Court held that the FSIA did not provide immunity to a Turkish state-owned bank, Halkbank, for criminal charges, and that the bank could be prosecuted for evading U.S.-imposed economic sanctions against Iran.

The United States Supreme Court decided for the first time that foreign sovereigns and foreign-owned entities are subject to criminal prosecution in United States courts, rejecting the contentions of a Turkish state-owned bank that it was immune from prosecution under the Foreign Sovereign Immunities Act (“FSIA”).  

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.

The Lafarge case illustrates the extent companies with operations in high-risk jurisdictions must be aware of increasing ATA-related risk, including the risk of civil litigation.

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.

Non-US insurers with exposures to Iran-related business face a difficult six months to bring their business into compliance with US president Donald Trump’s newly reinstated snap-back sanctions

On April 18, 2017, the International Islamic Relief Organization of Saudi Arabia (“IIROSA”) launched a major humanitarian distribution of food and other necessities in refugee camps in Juba, South Sudan to alleviate the plight of the South Sudanese affected by the famine. The distribution of the approximately $250,000 worth of much needed aid from IIROSA – including food items such as flour, sugar, corn, oil, and dried milk, as well as other basic goods – was made in conjunction with the South Sudanese Ministry of Humanitarian Affairs and a local charity partner.

Mr. Francos is a contributing author.

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.

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.

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.

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

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.

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.

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.

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."

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.

Banks serving clients in the many countries the U.S. views as high risk for money laundering should be aware that the U.S. Financial Crimes Enforcement Network (“FinCEN”), a bureau of the U.S. Department of the Treasury, plans to expand its use of “special measures” to fight money laundering and terrorist financing. Per its 2020 budget and performance report, FinCEN expects by 2022 an increase of 30% in its use of “special measures,” including those authorized by § 311 of the USA PATRIOT Act (“§ 311”).

Eric Lewis focuses on three key areas: (1) the widening of the net from sanctioned individuals to their families; (2) the application of the evasion provisions to foreign persons; (3) the bringing of new classes within existing sanctions.

We are pleased to report that on August 16, 2016, the United States Treasury Department removed the Philippines and Indonesia branch offices of our client, the International Islamic Relief Organization of Saudi Arabia (IIROSA) from the Office of Foreign Assets Control Specially Designated Nationals (SDN) list. The administration’s action in this matter demonstrates a clear commitment to an impartial review of the facts and its belief in IIROSA’s ability to oversee its critical global relief operations.