Sean C. Kane is counsel in Hughes Hubbard’s International Trade practice. He is a former Deputy Assistant Director for Policy in the Office of Foreign Assets Control (OFAC) in the U.S. Department of the Treasury, where he played a leading role in several high-profile sanctions initiatives, including the development and implementation of the Russia sanctions program and the recent easing of sanctions against Sudan. Working alongside the Assistant Director for Policy at OFAC, Sean oversaw a team of sanctions policy advisors and worked directly with the OFAC director and Undersecretary of the Treasury for Terrorism and Financial Intelligence to develop and implement sanctions measures across more than 30 portfolios, including those related to Iran, Russia, Cuba, Sudan, North Korea, counterterrorism, and counter-narcotics. He frequently led outreach to foreign governments and the private sector to coordinate the implementation of sanctions policies and to facilitate compliance with existing measures in the United States, Europe, Asia, and Africa.
He also played a leading role in shaping the development of new sanctions authorities, OFAC regulations, and policy guidance, coordinating closely with interagency partners at the National Security Council (NSC), U.S. Department of State, and the Bureau of Industry and Security at the U.S. Department of Commerce. Sean also regularly engaged with Congress on pending or proposed sanctions legislation, and worked closely with colleagues at the Treasury Department on Anti-Money Laundering (AML) issues, as well as Committee on Foreign Investment in the United States (CFIUS) matters.
Prior to this role, Sean worked as Senior Sanctions Policy Advisor at OFAC, where he developed policy for consideration by senior Treasury officials and served as a primary interagency liaison for the NSC, Department of State and Intelligence Community. He also served as a License Examining Officer in the Office of Foreign Assets Control in the Treasury.
Earlier in his career, Sean worked as Head of Risk Consultancy at the AKE Group in London, and as a Global Risk Analyst in the London office of Merchant International Group.
Quotes & Interviews
Quoted in “White House Authorizes Secondary Sanctions Against Overseas Banks Tied to North Korea,” Association of Certified Anti-Money Laundering Specialists (ACAMS) moneylaundering.com, September 21, 2017
Quoted in “More Designated Parties See Names Removed from US Blacklists: Sources,” Association of Certified Anti-Money Laundering Specialists (ACAMS) moneylaundering.com, September 12, 2017
Speaker, " Sanctions," New Hampshire Public Radio’s Civics 101 Podcast, August 18, 2017
Quoted in “Trump Blasts Russia Sanctions Bill, But Still Signs It,” Associated Press, August 2, 2017
Quoted in “As Trump Signs Russian Sanctions Law, Market Yawns and Germans Panic,” Forbes.com, August 2, 2017
Quoted in “OFAC deputy assistant director for policy joins Hughes Hubbard,” Global Investigations Review, May 18, 2017
Quoted in “Trump Administration Keeps ‘Status Quo’ on Iran Sanctions,” Wall Street Journal, May 17, 2017
Quoted in “US extends Obama-era sanctions relief for Iran,” The Hill, May 17, 2017
Quoted in “Hughes Hubbard Adds Sanctions Expert From Treasury OFAC,” Law360, May15, 2017
Highlighted Publications and Lectures
"Trump Administration on Sanctions: Priorities and Changes in Tone," The Export Practitioner (February 2018)
Co-author, with Susie Park, “OFAC Enforcement Trends in 2017: Exporters on Notice,” Law360 (January 2018)
“Iran and Russia: Future Proofing Your Sanctions and Export Compliance Programs,” Compliance Week, webinar, November 7, 2017
"Office of Foreign Assets Control Licensing Requirements and Sanctions," Society for International Affairs 2017 Fall Advanced Conference, Virginia, October 23, 2017
"OFAC Enforcement Trends: Exporters in the Crosshairs," Export Compliance Training Institute, webinar, October 12, 2017
"Developing a Compliance Strategy for Doing Business in Iran," TRACE 2017 European Forum, London, UK, November 3, 2017
“The Future of U.S. Sanctions On Iran: What You Should Do Amidst Uncertainties,” The Knowledge Group, webinar, November 9, 2017
"Cooks in the Kitchen: How the Sanctions Get Made," The Export Practitioner (August 2017)
Co-author, with Joseph Schoorl, “Defining OFAC Property Interests Beyond The 50% Rule,” Law360 (June 2017)