US Sanctions

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.

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.

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.