Olivier Dorgans is a Counsel within Hughes Hubbard’s Sanctions, Export Control & Anti-Money Laundering practice group. Olivier has over ten years of experience and focuses on compliance, global investigations and, more generally, on financial and regulatory crime. His practice covers a wide spectrum of criminal and regulatory issues ranging from economic sanctions and export control rules to the fight gainst corruption, money laundering and terrorist financing.

Olivier has developed significant experience in internal investigations – notably based on the extraterritorial application of U.S. and U.K anti-corruption, anti-money laundering, and economic sanctions rules – and has advised and represented numerous clients on these matters.

Olivier also assists financial institutions and large industrial groups in designing and implementing global compliance programs. As such, he focuses on providing practical compliance advice consistent with best practices and local regulations. Olivier regularly conducts compliance training, notably on corruption, economic sanctions and money-laundering risks.

Finally, Olivier advises and represents French and European clients in proceedings before various French, European and American regulators.

Prior to joining Hughes Hubbard and Reed, Olivier worked in leading US firms.

Highlighted Lectures

Speaker on RegTechs (FinTechs focusing on regulatory activities) and compliance at the DLA TechDay, October 2016
Speaker on the upcoming French anti-corruption reform at the 34th Cambridge International Symposium on Economic Crime, September 2016
Speaker on the Fourth Anti-Money Laundering Directive at the Risk and Compliance Conference "Loi Sapin 2 : vers un monde sans corruption" organized by Thomson Reuters and the AFJE, July 2016
Webinar on the Loi Sapin 2 and its impact on compliance program for French financial and industrial companies, May 2016
Speaker on the Fourth Anti-Money Laundering Directive at the ACAMS 12th Annual AML & Financial Crime Conference Europe, May 2016
Speaker on U.S. economic sanctions and impact on due diligence processes at the ACAMS 12th Annual AML & Financial Crime Conference Europe, May 2016
Speaker on U.S. and EU economic sanctions against Russian and Iranian economic interests at the ACAMS Training Seminar "Mastering Sanctions: Effective Strategies for Managing Rapid Global Changes", December 2015

Highlighted Publications

Co-author with Ryan Fayhee, Alan Kashdan, Tyler Grove, and Clothilde Humbert, "The Global Magnitsky Act: Sanctions in Response to International Crises," WorldECR (December 2018)
Revue internationale de la compliance et de l’éthique des affaires, Le Cloud Act: nouvel instrument de guerre renforçant l’ingérence des autorités américaines sur les prestataires de services de communication électroniques américains, 2018
Co-author with Paul Charlot, Revue internationale de la compliance et de l’éthique des affaires, Le retrait des Etats-Unis du JCPOA et le rétablissement des sanctions américaines, July 2018
Co-author with Paul Charlot, Option Finance, Rachat de parts d'OPCVM: les nouveautés introduites par la Loi Sapin 2, November 2016
Magazine des affaires – Guide CAC 40, Les entreprises françaises face aux nouveaux enjeux de compliance : contrainte ou opportunité ?, September 2016
Conseils et Entreprises, Projet de Loi Sapin II: Introduction d’une obligation de prévention des risques de corruption, June 2016
Cyber Security Law & Practice, Co-author, Recent French developments raise the heat on encryption, June 2016
Option Droit & Affaires, La loi Sapin II: simple évolution ou véritable transformation du dispositif anticorruption ?, March 2016

Speaking Engagements

Lecturer concerning the French anticorruption framework following the enactment of the Sapin II bill, Master 2 de droit des affaires internationales de l’Université Paris Saclay, April 2018
Lecturer on economic crime compliance at the Paris Institute of Political Studies (Sciences Po, Master 2 droit économique), January - May 2017
Speaker on the Sapin 2 bill at the Paris Institute of Political Studies (Sciences Po, Master 2 finance et stratégie), September 2016

Recognitions

Winner "rising team" prize for the category Regulatory & Compliance at the Leaders Leagues Law Trophies (Trophées du Droit) 2018
Ranked in the Excellent category (2nd tier) of the Décideurs 2017 Ranking for best law firms in Regulatory & Compliance (Enquête interne et programme de conformité)

Anticorruption and AML-TF Experience

Highlighted Matters

Assisted a French financial institution and a French defense company following an control conducted by the French anti-corruption Agency
Assisted a major French defense actor, a large French pharmaceutical group, a French retail and international insurance company in the design and implementation (including related training) of compliance programs
Assisted a major French defense actor, a public financial institution and several international insurance companies in anti-corruption, AML/FT and economic sanctions risk assessments
Assisted a German FinTech on French KYC requirements before the French Autorité de Contrôle Prudentiel et de Résolution (ACPR)
Assisted a French company in the context of an FCPA and French anti-corruption regulation global investigation led by the DoJ with the assistance of the French Service Central de Prévention de la Corruption (SCPC)

Economic Sanctions and Export Control

Assisted a French SME in the handling of all its contracts presenting ties with Iran following the re imposition of US secondary sanctions
Assisted a large French public financial institution in general sanctions advice, policies and procedures overhaul, and licensing in the context of EU and U.S. sanctions against Iranian economic interests
Assisted a public financial institution in general sanctions advice, policies and procedures overhaul for all their export finance operations
Assisted a mid-size international bank in an Office of Foreign Assets Control (OFAC) investigation into potential violations of U.S. sanctions
Represented a large French financial institution in the context of a five-year long investigation into violations of U.S. sanctions led by OFAC, the Department of Justice (DoJ), the New York County District Attorney’s Office (DANY), the New York Federal Reverse Bank (NY Fed) and the New York State Department of Financial Services (NYSDFS) and spanning across five jurisdictions
Advised European, American and Russian financial and industrial companies on the impact of U.S. and EU sanctions against Russian economic on contemplated transactions and joint-ventures

Foreign Investments in France

Assisted before the competent French regulatory authority a foreign investment fund though the acquisition of a French company conducting activities subject to foreign investment authorization regime
Assisted before the competent French regulatory authority an American company purchasing a French company conducting activities subject to foreign investment authorization regime

Force majeure et mesures conservatoires à l’épreuve des mesures de gel des avoirs européennes

Olivier Dorgans

Counsel