Economic Sanctions

  • Clearstream Banking S.A. We represented Clearstream, in a landmark settlement reached in January 2014 between Clearstream and the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) of $152 million, a reduction of more than fifty percent from the originally contemplated penalty. We also advised Clearstream on the enhancement of its sanctions compliance program, which has set new standards for the industry. Davis Polk continues to represent Clearstream in complex issues regarding the partial lifting of sanctions against Iran and the targeted sanctions against Russia and the Crimean region of Ukraine.
  • Intesa Sanpaolo. We represented Intesa Sanpaolo, in connection with an industry-wide, multiyear criminal and civil investigation by the U.S. Department of Justice, the Manhattan District Attorney’s Office, and OFAC into alleged violations of U.S. sanctions and other laws arising from the processing of USD transactions relating to Iran, Cuba, Libya and Sudan. In a landmark decision, the DOJ and the Manhattan DA determined not to pursue any criminal charges or impose any fines or other penalties against our client.
  • JPMorgan Chase. We represented JPMorgan Chase Bank in connection with its $88 million settlement with OFAC for potential violations of multiple sanctions programs related to doing business with Cuba, Iran, Sudan and others. 
  • ABN AMRO. We represented ABN AMRO in connection with a DOJ criminal investigation into the bank’s dollar-clearing activities, OFAC compliance procedures and other Bank Secrecy Act compliance matters. We represented ABN AMRO and some of its successors/acquirers through the post-settlement compliance and look-back process, and also continue to represent the bank on sanctions compliance, including complex trade finance, futures and hedging transactions involving Russia.
  •  Euroclear Bank. We advise Euroclear and its affiliates on U.S. economic sanctions issues, including complex matters arising out changing regulations affecting Iran, Libya and Russia.
  • S&P Global. We advise S&P Global on a range of sanctions issues across the globe relating to the company’s sale of specialized information services and data, its information gathering and its journalistic activities. In addition, we provide assistance on sanctions issues in connection with the company’s mergers and acquisitions activities. We are also assisting S&P Global in meeting its SEC disclosure obligations regarding its global activities.
  • Financial Institution. We represent a major Asian financial institution in connection with a U.S. subpoena response regarding the bank’s practices for U.S. dollar-denominated payments associated with persons or jurisdictions targeted by U.S. sanctions.
  •  Professional Services. We have provided compliance and other regulatory advice to major professional services companies, multinational consumer products companies, international insurance companies, and global natural resources companies relating to U.S. economic sanctions administered by OFAC. 
  • Credit Card Issuers. We have represented major domestic and foreign credit card issuers and processors in filing voluntary self-disclosures to OFAC in connection with credit card transactions involving Cuba and the EU and Canadian blocking measures prohibiting compliance with U.S.-Cuba sanctions. 
  • U.S. and European Financial Institutions.  We provide ongoing advice to several major U.S. and European financial institutions with respect to compliance, licensing, transactions, and other regulatory issues relating to economic sanctions laws, including with respect to the U.S. Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010 (CISADA), the sanctions provisions of the National Defense Authorization Act for Fiscal Year 2012 (the “NDAA”), and other pending and enacted legislation and Executive Orders.