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Understanding Economic Sanctions for Banks and Financial Institutions
Gerard (Jerry) W. LiVigni
Senior Compliance Officer, Office of Foreign Assets Control (OFAC)
U.S. Department of the Treasury
Mr. LiVigni has over 28 years of International Banking Operations, Anti-Money Laundering, and Bank Secrecy Act compliance experience. Before joining OFAC Jerry was Vice President and Compliance AML Training Officer for BNP Paribas’s bank and securities affiliate offices in the United States. He was responsible for USA PATRIOT Act AML policies and procedures as well as monitoring BSA and OFAC examination work programs, the “Firm” element and the Annual Firm meeting and training of registered representatives and floor traders at the New York Futures Commodity Mercantile Exchange.
Mr. LiVigni is a key member of the Compliance Outreach and Implementation team at the Treasury Department’s Office of Foreign Assets Control and plays a front line role in the financial war against international terrorists and narcotics traffickers. He provides practical advice on a daily basis to financial institutions from around the world on OFAC compliance issues, routinely interacting with his regulatory and private industry peers.
Jerry believes that the hallmark of addressing OFAC issues either as a financial institution or a “person” who comes under OFAC jurisdiction, one ought to rely on an ethical “clear and reasonable approach” in both their risk assessment and its application. Since 2003 Mr. LiVigni has been a regular presenter at the Federal Financial Institutions Examination Council (FFIEC Institute’s) AML Workshop’s OFAC module. In addition since 2003 Mr. LiVigni has been a regular speaker at the Annual Money Transmitter Regulators Association (MTRA) Conference for MSB State Regulators and Examiners and the MSB industry along with his addressing the International Money Transmitters Convention. Mr. LiVigni was a keynote speaker at the Conference of State Bank Supervisors (CSBS) BSA/AML Emerging Issues Forum. Since 2005 Jerry has been a regular presenter at the NASD (now FINRA) Institute’s Anti-Money Laundering Symposium for OFAC related responsibilities and their impact on the securities industry. In October 2007 and again in November of 2008 Mr. LiVigni was a panelist at the half-day SIFMA and OFAC Symposium specifically addressing OFAC issues with regard to screening of the SDN and Blocked Persons List and implications for the Securities Industry. Since 2006 Mr. LiVigni has been a presenter at the Annual Puerto Rico Bankers Association Symposium on Anti-Money Laundering. For the last three years he has addressed the American Payroll Association’s Capital Summit in Washington, D.C.
Mr. LiVigni has a B.A. degree from York College of the City University of New York. He also holds a New York State Teaching Certification.
Scott Maberry
Partner
Fulbright & Jaworski LLP
J. Scott Maberry is the head of the International Trade practice group of Fulbright & Jaworski L.L.P. His expertise includes counseling and litigation in economic sanctions, export controls, anti-terrorism, anti-bribery, anti-boycott controls, and Customs. He is the immediate past chair of the American Bar Association Committee on Export Controls and Economic Sanctions, and is the co-chair of the ABA National Institute on Economic Sanctions.
His practice includes representing clients in criminal and civil investigations conducted by various agencies, including federal grand juries, the U.S. Department of Treasury Office of Foreign Assets Control (OFAC), Department of Commerce Bureau of Industry & Security (BIS), the Department of State Directorate of Defense Trade Controls (DDTC), the International Trade Commission (ITC), the Committee on Foreign Investment in the United States (CFIUS), and WTO and NAFTA dispute resolution panels.
Mr. Maberry served as Visiting Counsel to General Electric in New Delhi, India, from 1996 to 199 and as Clerk to Judge Arlin M. Adams, U.S. Independent Counsel, from 1990 to 1993.
Alison Clew
Principal, Forensic & Dispute Services
Deloitte Financial Advisory Services LLP
Ms. Clew is a Principal in the Global AML/ETS practice of Deloitte Financial Advisory Services LLP, Boston Office. She focuses on matters relating to procedural and transactional compliance with USA PATRIOT Act and non-US AML regulations and OFAC and other sanctions regulations in the financial services industry, including global banks, major investment banks, broker/dealers and asset managers. Alison has assisted clients in addressing significant AML and sanctions program issues, leading efforts to analyze and suggest improvements to clients’ economic sanctions monitoring programs, policies, procedures, filtering systems, list management and operational management of alerts.
John B. Reynolds, III
Partner
Wiley Rein LLP
Mr. Reynolds advises U.S. and foreign corporations, financial institutions, defense companies, technology companies, consumer products companies, government -owned corporations and sovereign wealth funds on trade, privacy, security and regulatory issues. He frequently represents clients before the U.S. Departments of State, Treasury, Commerce, Defense and Homeland Security and the Office of the U.S. Trade Representative. With over twenty years of experience in export controls and economic sanctions, he counsels across industry sectors concerning all types of international compliance and enforcement issues.
Mr. Reynolds has been rated in the nation’s top tier of international trade attorneys by Chambers USA, which acknowledges him as a Committee on Foreign Investment in the United States (CFIUS) expert and calls him a “star of Wiley Rein’s highly rated export controls and economic sanctions team.” Chambers further notes that “he is perfectly placed to provide high-level advice to the financial institutions that increasingly come knocking on his door when in need of compliance expertise.”
Mr. Reynolds handles international investment transactions, acquisitions, joint ventures, privatizations and international telecommunications regulations and treaties. He also counsels clients on administrative proceedings, trade policy and foreign acquisitions of U.S. defense and critical infrastructure companies, including negotiating network security agreements, and international privacy law, including European Union privacy directives and the U.S. Safe Harbor Program. Mr. Reynolds provides the full range of economic sanctions and anti-money laundering services, including risk assessments, transaction counseling, compliance programs, licensing, lobbying and defense of enforcement actions.
Mr. Reynolds was an Attorney-Adviser for the U.S. Department of State, Office of the Legal Adviser from 1982-1988 and member of the American Bar Association (ABA).
Understanding Economic Sanctions for Banks and Financial Institutions
Speaker Firms and Agency:
U.S. Department of the Treasury
Wiley Rein LLP
Upcoming events.