What is your main area of practice?
OFAC Attorney: My main area of practice is in economic sanctions that are administered by the Office of Foreign Assets Control, which is commonly called OFAC. I also practice white collar criminal defense and export controls law, which often intersects with OFAC sanctions.
What types of cases do you typically handle?
OFAC Attorney: OFAC sanctions cases encompass the whole spectrum of legal practice. It can be very administrative in terms of doing compliance work or getting a license for a person or company to do a specific transaction. It can also involve criminal litigation in cases where I’m defending someone who is being criminally charged for violating OFAC sanctions or other trade controls. Sometimes there is also investigative work involved whereby I serve as an internal investigator and look for possible violations within a company, and then determine whether it is appropriate for that company to voluntarily disclose that violation to OFAC.
Why did you choose OFAC law for your career?
OFAC Attorney: I chose to handle OFAC sanctions after I was exposed to it for the first time, right after law school. I graduated and went to work at a well-known white collar and federal criminal defense law firm where I started working on sanctions cases. I found it very interesting, the intersection of criminal defense, national security law, and foreign policy. When you work with interesting laws, the practice can be very rewarding in two ways: (1) you get to help people carry out transactions that are important to them, and (2), it is rewarding in an intellectual and academic sense.
What places where you have worked or trained in the past prepared you for a career in OFAC law?
OFAC Attorney: Previously, I spent three years working at a boutique law firm that practiced primarily in OFAC sanctions work and white collar criminal defense. We took on every type of sanctions related case at that firm and I handled every task imaginable related to OFAC sanctions, whether it was regulatory work and licensing or providing compliance services for somebody who needed to make sure their transaction was safe. We also did a lot of due diligence and investigating to make sure that international transactions did not involve people or countries that are targeted for sanctions. If a transaction involved such persons or countries it could cause a lot of problems for the company because, for example, a payment could be rejected or blocked.
What makes your approach to OFAC cases unique?
OFAC Attorney: I am very solution-oriented. When someone comes to an attorney, it is usually because either they are worried that something is going to go wrong or something has already gone wrong. I always take the approach of solving the issue or potential issue that is worrying the client. I listen to what the client has to say and then I use my knowledge of the law to find a solution, whether that is a compliance problem or whether they just got served a subpoena and they are concerned about being investigated. I distill down all the facts to determine what is needed to get the job done for the client.