Jeremy P. Paner

Economic Sanctions Compliance

• Ongoing representation of foreign multinational financial institution to advise on its OFAC compliance policies and procedures, and lines of business in light of evolving sanctions risk, including USD transactions outside the United States.

• Ongoing representation of U.S. subsidiary of a global producer of critical materials to mitigate enhanced risk acquisitions.

• Ongoing representation of a major European and Middle East energy investor in connection with litigation in Europe, the Middle East, and Asia.

• Guided one of the world’s largest tanker owners and operating companies through existential Russia-related risk exposure with no adverse action taken by the United States.

• Provided ongoing sanctions compliance advice to a bank within the U.S. Federal Reserve.

• Regularly advised a Middle Eastern Central Bank on matters involving significant sanctions and political risk exposure.

• Advised a Europe-based investment bank on sanctions exposure arising from complex and high-profile transactions.

• Counseled multinational private equity fund management companies on sanctions exposure relating to limited partners, disbursements, and investments.

• Assisted a global manufacturer of construction and mining equipment, and industrial gas turbines with enhanced due diligence reviews of proposed projects, sales, and service requests.

Economic Sanctions Investigations

• Successfully represented a European bank before OFAC responding to a subpoena relating to potential apparent sanctions violations, resulting in a No Action Letter from OFAC Enforcement.

• Resolved significant sanctions exposure for a global specialized software company through submission of an OFAC voluntary self-disclosure, resulting in a private Cautionary Letter and no penalty.

• Represented an international facility management provider through an OFAC voluntary self-disclosure that resolved significant sanctions risk exposure with no public notification or penalty.

• Substantive lead on multi-year risk review and assessment of accountholders of a Middle East-based bank under OFAC monitorship.

• Led multinational investigations and audits of potential apparent sanctions violations for a global materials science company, while simultaneously identifying and assisting in the implementation of opportunities to enhance the company’s compliance program.

• Directed multinational investigations and audits of potential apparent sanctions violations for a global petroleum products supplier, while simultaneously identifying and assisting in the implementation of opportunities to enhance the company’s compliance program.

OFAC Specific License

• Obtained authorization for a global leader in industrial uninterruptible power supply systems to remit payment involving a country subject to comprehensive sanctions necessary for closing a buy-out by a private investment fund. 

• Obtained seven separate OFAC licenses for one of the largest banks in the Middle East to release funds blocked by U.S. intermediary banks. 

• Successfully obtained authorization for a multinational industrial manufacturer to provide parts and services necessary for electricity production and transmission to a government entity subject to sanctions.

• Obtained authorization for a global commodities trading corporation to enforce a significant arbitral award involving a country subject to comprehensive sanctions.

• Obtained multiple separate authorizations for a global petroleum products supplier to engage in otherwise prohibited transactions necessary to divest from and exit Russia.

• Obtained authorization for a global marketing company to engage in otherwise prohibited transactions necessary to exit Russia. 

Economic Sanctions Training

• Conducted weekly Russia-related sanctions briefings for a publicly traded, multinational diversified engineering business during its one-year exit from Russia.

• Continually updated and enhanced U.S. sanctions compliance training materials for a leading provider of global trade compliance training solutions.

• Provided training on OFAC procedures to the UK Office of Financial Sanctions Implementation (OFSI).

• Provided annual OFAC compliance and risk exposure assessment training sessions to the board of one of the largest commercial banks in the Middle East. 

• Provided annual OFAC compliance training for two of the largest Chinese banks.  

Miscellaneous Economic Sanctions Engagements

• Represented or formally advised on OFAC delisting petitions resulting in the removal of sanctions imposed against about 55 individuals and companies previously sanctioned under various authorities, including the Transnational Criminal Organization, Counternarcotics, and Russia-related programs. 

• Worked with a major international humanitarian aid group to successfully advocate for several OFAC general licenses and multiple Frequently Asked Questions that reestablished access to the U.S. financial system necessary for ongoing large-scale projects.

• Provided a global chemical engineering and technology company with an expert report and testimony on Iran-related U.S. economic sanctions in a major international arbitration, leading to a favorable award for that company.

• “U.S. Sanctions Trends and Developments Multinationals Will Confront in 2026,” Dow Jones Risk Journal, Jan. 26, 2026.

• “How Multinationals Should Address Ongoing U.S. Sanctions Enforcement Priorities,” Dow Jones Risk Journal, Oct. 10, 2025.

• “Handling Sanctions Risk Cartel Control Brings To Mexico Port,” Law 360, Aug. 8, 2025.

• “In the dock: Goetz decision sheds light on OFAC delisting criteria,” WorldECR Issue 139 May 2025

• “A Look at U.S. Economic Sanctions on Russia,” Transatlantic Law Journal, Vol. 3, Issue 3, May 2025.

• “Cos. Should Prepare For Mexican Payments Surveillance Tool,” Law360, March 11, 2025.

• “Critical Steps For Navigating Intensified OFAC Enforcement," Law360, Feb. 6, 2025. 

• “What New Syria Sanctions Mean For US Companies,” Law360, June 24, 2020.

• “Next US Move Against Iran Could Block Humanitarian Aid,” Law360, Aug. 15, 2019.

• “Compliance Certifications Jack Up Sanctions Violation Costs,” Law360, April 30, 2019.

• “Trump’s Border Emergency Declaration May Undermine Economic Sanctions,” Bloomberg Law, March 6, 2019.

• “OFAC Eases Burma Sanctions, But Risks Remain,” Law360, June 6, 2016.

• “Lessons From OFAC’s First Public ‘50 Percent Rule’ Penalty,” Law360, Feb. 19, 2016.

• Quoted in “Proceed With Caution: Lawyers Advise International Companies Exploring Business in Venezuela,” Law.com, May 6, 2026.

• Quoted in “BP License to Work With Iranian, Russian Partners in Azeri Gas Field Extended by US,” Bloomberg, May 6, 2026.

• "Trump expands US sanctions on Cuban government and affiliates," Reuters, May 1, 2026.

• “US sanctions enforcers get real about fake transactions,” Global Investigations Review, April 16, 2026.

• “FinCEN Moves Against Swiss Bank Over Russia and Iran Ties, Triggering Liquidation,” Financial Crime Digest, April 6, 2026.

• “U.S. allows Russian oil tanker to reach Cuba, breaking Trump’s effective blockade,” The Washington Post, March 30, 2026.

• “The Trail of Clues Leading to Iran That Binance Missed,” New York Times, March 26, 2026.

• “As Cuba moves to open economy, U.S. restrictions remain a roadblock,” WLRN (South Florida NPR), March 23, 2026.

• “US Further Eases Venezuela Oil Sanctions,” Energy Intelligence, March 18, 2026.

• “OFAC temporarily lifts sanctions on certain Russian oil shipments,” Compliance Week, March 16, 2026.

• “US Allows Venezuela to Sell Fertilizers as War Crimps Supply,” Bloomberg, March 13, 2026.

• "Proposed FINCEN rule would sever Swiss bank from US banking system," WorldECR, March 2026.

• “Many Questions, Few Facts Surround Carlyle's Lukoil Deal,” Energy Intelligence, Feb. 10, 2026.

• “Venezuela Sanctions Relief Has 'America First' Bent,” Energy Intelligence, Jan. 30, 2026.

• “US lifts some Venezuela sanctions to ease oil sales,” Reuters, Jan. 29, 2026.

• “US moves to open Venezuela’s vast crude reserves to Big Oil,” Financial Times, Jan. 29, 2026.

• “‘Not Your Standard’ Screening: Venezuela Fraught With Risks Despite Sanctions Hint,” Global Investigations Review, Jan. 14, 2026.

• “Skipper seizure ‘based on IRGC connections not designation," World ECR, Jan. 2026.

• “Chevron-Quantum Join Bidding for Lukoil Assets,” Energy Intelligence, Jan 7, 2026.

• “Trump’s Seizures of Oil Tankers Challenge Maritime Rules and Customs,” The New York Times, Dec. 24, 2025.

• “Exclusive: US intercepts oil tanker off Venezuelan coast, officials say,” Reuters, Dec. 21, 2025.

• “Coast Guard boards oil tanker leaving Venezuela amid Trump’s blockade,” The Washington Post, Dec. 20, 2025.

• “Trump announces 'complete blockade' of sanctioned oil tankers to Venezuela,” The Washington Post, Dec. 16, 2025.

• “White House signals campaign to seize more oil tankers near Venezuela, The Washington Post, Dec. 12, 2025. 

• “Businesses’ road to Damascus lined with legal risks, lawyers say,” Global Investigations Review, Nov. 26, 2025.

• “US Terror Label in Venezuela Deepens Risk for Oil Companies,” Bloomberg, Nov. 25, 2025.

• “Strange Bedfellows: How a Supreme Court Ruling Found Its Perfect Match in the Trump Administration,” Corporate Compliance Insights, Nov. 19, 2025.

• “US paves way for talks on sale of Lukoil's foreign assets,” Reuters, Nov. 15, 2025. 

• “US Treasury Issues Sanctions Waivers for Certain Lukoil Sales,” Energy Intelligence, Nov. 14, 2025.

• “US Extends Lukoil Sanctions Waiver as New Bidders Emerge,” Bloomberg, Nov. 14, 2025. 

• “Brazil cuts reliance on Russian diesel amid new US oil sanctions,” Financial Times, Nov. 11, 2025.

• “Trump’s Belated Sanctions Rattle Russian Oil Sector,” Energy Intelligence, Oct. 30, 2025. 

• “New Russia oil sanctions leave little room for interpretation,” Global Investigations Review, Oct. 27, 2025. 

• “Cambodian ‘scam center’ crackdown’s promise of closer US-UK action is unclear,” MLex, Oct. 24, 2025.

• “Oil supply glut paves way for Donald Trump to tighten screws on Russia,” Financial Times, Oct. 24, 2025. 

• “Trump’s turnaround on sanctions targets Russia’s oil companies that fund the war in Ukraine,” Associated Press, Oct. 23, 2025. 

• “US hits top Russian oil companies Rosneft and Lukoil with sanctions,” Reuters, Oct. 22, 2025.

• “Trump Will Boost Russia Sanctions After Putting Off Putin Summit,” Bloomberg, Oct. 22, 2025.

• “Magnitsky Act Puts Brazilian Banks in a Billion-Dollar Dilemma,” Veja Negócios, Sep. 27, 2025.

• “Banco do Brasil Mulls Range of Options If US Escalates Sanctions,” Bloomberg, Sep. 3, 2025.

• “Brazilian banks caught in Trump’s crossfire with judge,” Financial Times, Sep. 3, 2025.

• “Trump's options to ease Russia sanctions limited compared to Europe’s,” Reuters, Aug. 28, 2025.

• “US oilfield services group expands Russian unit despite new sanctions,” Financial Times, Aug. 21, 2025.

• “OFAC issued rare law firm rebuke in GVA case,” Global Investigations Review, Aug. 8, 2025.

• “Thanks to ‘laser focus’ on cartels, Trump admin creates new corporate risks in Mexico,” Compliance Week, Aug. 6, 2025.

• “Trump unlikely to enforce tariff threat on Russian oil,” Reuters, July 25, 2025.

• “Sanctions, on Rise, Are as Deadly as Armed Conflict, Study Says,” Bloomberg, July 22, 2025.

• “Trump signals shift in policy, allows China to buy Iranian oil,” Reuters, June 24, 2025.

• “US imposes sanctions on companies it says sent Iranian oil to China,” Reuters, May 13, 2025.

• “US targets China oil storage terminal in new Iran-related sanctions,” Reuters, April 11, 2025.

• “US tightens sanctions on Russian energy trade,” Global Trade Review, March 19, 2025.

• “US slaps sanctions on network shipping Iranian oil to China,” Reuters, Feb. 6, 2025.

• “Cartel Terrorist Designations Would Have Potentially Enormous Impact,” ACAMS Moneylaundering.com, Jan. 29, 2025.

• “US issues fresh round of sanctions against Russia ahead of Trump return to White House,” Reuters, Jan. 15, 2025.

• “US oil group under pressure to exit Russia after Biden administration widens sanctions,” Financial Times, Jan. 13, 2025.

• “US hits Russian oil with toughest sanctions yet in bid to give Ukraine, Trump leverage,” Reuters, Jan. 10, 2025.

• “US firm’s Russia work prompts Congress to demand stricter sanctions,” Financial Times, Oct. 19, 2024.

• “Sanctions Breaches Trigger Mishmash of US Enforcement Actions for Emirati Bank,” ACAMS MoneyLaundering.com, Nov. 10, 2021.

• “Fall of Afghanistan Leaves US Officials Scrambling Over Taliban Funding Streams,” ACAMS MoneyLaundering.com, Aug. 18, 2021.

• “Unpacking the Lafarge case study: Lessons for multinationals operating in high-risk environments,” Compliance Week, Nov. 2025.

• “FinCEN’s Recent Actions: Existential Threat for Financial Institutions in Mexico,” All Things Investigations Podcast, Compliance Podcast Network, Podcast Episode 76, Sept. 2025.

• “Measures Recently Imposed by the United States Government and the Risks They Represent for Mexican Companies,” Asociación Nacional de Abogados de Empresa (ANADE Nuevo Leon), Sept. 2025.

• “Terrorism Designations of Mexican Cartels Fundamentally Enhances Risk for All Companies,” All Things Investigations Podcast, Compliance Podcast Network, Podcast Episode 69, Mar. 2025.

• “FCPA and criminal organizations: Risks and Compliance for companies,” International Chamber of Commerce Mexico, March 2025.

• “A New Look at US Sanctions and Practical Guidelines for Compliance,” Schar School of Policy and Government, September 2022.

• “Doing Business in Cuba,” World Trade Center Denver, July 2017.

• “Doing Business in Iran,” The Finance, Credit & International Business Association, April 2017.

• “Opportunities and Legal Risks in the New OFAC Cyber-Related Sanctions Regulations Explored,” The Knowledge Group, April 2016.

• “Complying with New Russian Sanctions and How the 50 Percent Rule Could Affect Your Existing Business Relationships,” Foreign Corrupt Practices Act Boot Camp, American Conference Institute, January 2015.

• “Practical Implications to Minimize Facilitation Risks When Dealing with a New or Established Client,” Economic Sanctions Boot Camp, American Conference Institute, December 2015.