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Jeanine P. McGuinness
Associate
Ms. McGuinness is an associate in Davis Polk’s Corporate Department and works in the Washington DC office. She concentrates in U.S. trade and investment laws applicable to cross-border transactions, including U.S. economic sanctions, U.S. anti-money laundering laws, U.S. anti-boycott laws, the Exon-Florio statute and the Foreign Corrupt Practices Act. Her clients include major U.S. and foreign financial institutions, and pharmaceutical, technology, telecommunications, energy and natural resource companies. 
Contact
  • Washington DC
    901 15th Street, N.W.
    Washington, DC 20005
    P: 202-962-7150
    F: 202-962-7085
Bar Admissions
  • District of Columbia
  • State of New York
Education
  • B.A., Fairfield University, 1989
    • summa cum laude
  • J.D., Harvard Law School, 1992
    • cum laude

Work Highlights
  • Prepares voluntary self-disclosures, administrative subpoena responses and license applications to, and negotiates settlements with, the Treasury Department’s Office of Foreign Assets Control (OFAC)
  • Regularly advises underwriters and issuers in international capital markets transactions, and financial institutions and other companies in mergers and acquisitions and credit transactions, with respect to due diligence, representations and covenants, and appropriate disclosure regarding sanctions, anti-corruption and anti-money laundering issues
  • Advises clients regarding inquiries from the Securities and Exchange Commission (SEC) and state agencies implementing divestment laws
  • Frequently assists foreign private issuers in preparing sanctions-related disclosure for inclusion in annual reports (20-Fs)
  • Assists foreign purchasers of U.S. companies in navigating the Committee on Foreign Investment in the United States (CFIUS) approval process, including preparation of notices, meetings with CFIUS member agencies and guiding clients through follow-on investigations
  • Assists clients in developing and updating economic sanctions and anti-corruption compliance policies and procedures
  • Frequently drafts and negotiates OFAC and anti-money laundering provisions in private equity funds’ and hedge funds’ subscription materials
  • Regularly advises private equity and hedge funds regarding U.S. anti-money laundering laws and regulations and appropriate levels of due diligence on prospective investors, including enhanced due diligence on high risk investors
Professional History
  • Associate, 1992-1998; 2005-present