Jeanine P. McGuinness
  1. Counsel

Ms. McGuinness is counsel in Davis Polk’s Financial Institutions Group and the economic sanctions and national security practice. She practices in the firm’s Washington DC office, where she concentrates in U.S. trade and investment laws applicable to cross-border transactions, focusing on U.S. economic sanctions, anti-money laundering laws, anti-boycott laws, the Foreign Corrupt Practices Act (FCPA) and transaction reviews by U.S. national security agencies, including the Committee on Foreign Investment in the United States (CFIUS). Her clients include major U.S. and foreign financial institutions, and pharmaceutical, technology, telecommunications, energy and natural resources companies.

Work Highlights

  • Represents clients in preparing voluntary self-disclosures, administrative subpoena responses and license applications to, and represents companies in connection with enforcement actions by, the Treasury Department’s Office of Foreign Assets Control (OFAC)
  • Provides policy and compliance advice to clients affected by frequent changes in U.S. sanctions, including sanctions targeting Iran, Cuba and Russia/Ukraine
  • Assists foreign purchasers of U.S. companies in national security reviews, including navigating the CFIUS process, through preparation of notices, meetings with CFIUS member agencies, advising on follow-on investigations, and negotiating and implementing mitigation agreements
  • Assists clients in developing and updating economic sanctions, anti-money laundering and anti-corruption compliance policies and procedures
  • Represents financial institutions in connection with U.S. federal and state enforcement actions regarding compliance with U.S. anti-money laundering laws and regulations
  • Represents lenders, underwriters, borrowers, and issuers in international lending and capital markets transactions regarding sanctions, anti-corruption and anti-money laundering issues
  • Advises U.S. trade association and its member banks regarding U.S. sanctions, anti-corruption and anti-money laundering issues in lending transactions, and prepares guidance for the industry on these matters
  • Advises financial institutions on the application of U.S. anti-money laundering regulations, with specific emphasis on customer identification program (CIP) / know your customer (KYC) / customer due diligence (CDD) requirements and suspicious activity reporting requirements
  • Regularly advises private equity and hedge funds regarding compliance with U.S. anti-money laundering and sanctions laws and regulations, including with respect to appropriate provisions in subscription materials and enhanced due diligence on high-risk investors
  • Advises clients regarding sanctions-related inquiries from the Securities and Exchange Commission (SEC) and state agencies implementing divestment laws; and assists clients in preparing sanctions-related disclosure for inclusion in annual reports to the SEC


Ms. McGuinness is a recognized leader in the legal industry:

  • Chambers USA - International Trade: CFIUS Expert: Nationwide
  • Chambers USA - International Trade: Export Controls & Economic Sanctions: Nationwide
  • “Jeanine McGuinness advises clients on CFIUS issues, in addition to economic sanctions and export controls matters. ‘I am continuously impressed by her extensive knowledge, excellent communication skills and her ability to wrap her subject matter expertise around the details of the matter and then drive conclusions or recommendations for next steps,’ says an interviewee.” – Chambers USA editorial

Of Note

  • Thought Leader on Financial Regulation, Davis Polk FinReg Blog, read Ms. McGuinness's posts
  • Frequent panelist at industry conferences on U.S. sanctions and anti-money laundering issues and developments

Professional History

  • Counsel, 2012-present
  • Associate, 1992-1998; 2005-2012

Bar Admissions

  • District of Columbia
  • State of New York


  • B.A., Fairfield University, 1989
    • summa cum laude
  • J.D., Harvard Law School, 1992
    • cum laude