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Jeremy P. Paner

Washington, DC

+1 (202) 721-4614

[email protected]
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Biography
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Jeremy is a partner in the Washington, DC, office of Hughes Hubbard. He represents clients in a wide range of industries on compliance with trade sanctions and national security-related matters, with particular focus on U.S. economic sanctions.

Jeremy has significant experience advising clients in industries including finance, cryptocurrency, asset management, heavy equipment, automotive, mining, media, entertainment, freight forwarding, electronics, food and beverage, communications and internet services, clothing and apparel, precious stones and gems, and defense. He has extensive experience with all issues arising from Office of Foreign Assets Control (OFAC) licensing, compliance and enforcement matters, and the designation and delisting process. Jeremy regularly advises clients on whether certain relationships and/or transactions are prohibited and/or sanctionable under U.S. law.

Jeremy, who spent most of his early career as a lead sanctions investigator and analyst for the Office of Global Targeting within OFAC, joins from an international Am Law 100 firm.

Jeremy has been cited by Reuters, The Financial Times, The Wall Street Journal, Bloomberg, BBC News, South China Morning Post, Compliance Week and ACAMS MoneyLaundering.com for insights into sanctions and related anti-money laundering developments. A frequent writer, Jeremy is the sole author of many assessments on sanctions law published by Bloomberg and Law360.

Highlighted Publications

  • Quoted in “US imposes sanctions on companies it says sent Iranian oil to China,” Reuters, May 13, 2025.
  • “In the dock: Goetz decision sheds light on OFAC delisting criteria,” WorldECR Issue 139 May 2025
  • Interviewed by Senior Correspondent Takeshi Togawa on NHK (Japan Broadcasting Corporation), May 9, 2025
  • Quoted in “US targets China oil storage terminal in new Iran-related sanctions,” Reuters, April 11, 2025.
  • Quoted in “US tightens sanctions on Russian energy trade,” Global Trade Review, March 19, 2025.
  • “Cos. Should Prepare For Mexican Payments Surveillance Tool,” Law360, March 11, 2025.
  • Interviewed by Alexis Conran on “Times Radio,” The Times and The Sunday Times, March 8, 2025.
  • "Critical Steps For Navigating Intensified OFAC Enforcement," Law360, Feb. 6, 2025. 
  • Quoted in “US slaps sanctions on network shipping Iranian oil to China,” Reuters, Feb. 6, 2025.
  • Quoted in “US issues fresh round of sanctions against Russia ahead of Trump return to White House,” Reuters, Jan. 15, 2025.
  • Quoted in “US oil group under pressure to exit Russia after Biden administration widens sanctions,” Financial Times, Jan. 13, 2025.
  • Quoted in “US hits Russian oil with toughest sanctions yet in bid to give Ukraine, Trump leverage,” Reuters, Jan. 10, 2025.
  • Quoted in “US firm’s Russia work prompts Congress to demand stricter sanctions,” Financial Times, Oct. 19, 2024.
  • Quoted in “Sanctions Breaches Trigger Mishmash of US Enforcement Actions for Emirati Bank,” ACAMS MoneyLaundering.com, Nov. 10, 2021.
  • Quoted in "Fall of Afghanistan Leaves US Officials Scrambling Over Taliban Funding Streams," ACAMS MoneyLaundering.com, Aug. 18, 2021.
  • “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.

Highlighted Speaking Engagements

  • “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.
Designation of Criminal Cartels as Foreign Terrorist Organizations Increases Compliance Risks for Companies (US or Not) Operating in Mexico and Greater Latin America
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Hughes Hubbard Announces New Cartel/Foreign Terrorist Organization Designations Taskforce
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Former OFAC Official Jeremy Paner Joins Hughes Hubbard’s Sanctions, Export Controls & Anti-Money Laundering Practice
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Education
  • The Pennsylvania State University, Dickinson School of Law, J.D., 2004
  • James Madison University, B.S., 2000
Bar Admissions
  • District of Columbia, 2016
  • Virginia, 2004
Areas of Focus
Banking & Financial Services
Global Investigations, Enforcement and Compliance
Sanctions, Export Controls & Anti-Money Laundering
White Collar & Regulatory Defense

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