Jeremy P. Paner
Locations
Bar Admissions
District of Columbia Virginia
Education
The Pennsylvania State University, Dickinson School of Law, J.D. James Madison University, B.S.
Jeremy is a partner in the Washington, DC, office of Hughes Hubbard. He represents clients in a wide range of industries on national security-related matters, with particular focus on U.S. economic sanctions.
Jeremy has significant experience advising and counseling Central and commercial banks, private equity fund managers, asset managers, energy sector investors and operators, global software development and IT companies and manufacturers, producers of critical materials, prominent tanker owners and operating companies, major defense companies, and international humanitarian aid groups, among many others.
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 processes. Jeremy regularly advises clients on both existing and anticipated political and sanctions risk exposure.
Jeremy, who spent his early sanctions career as a lead sanctions investigator for the Office of Global Targeting within OFAC, joins Hughes Hubbard from a global Am Law 50 firm.
Major print and broadcast media regularly interview Jeremy for his insight and analysis on sanctions developments, including the BBC, NHK (Japan Broadcasting Corporation), Times Radio, Reuters, Financial Times, Bloomberg, The Washington Post, and The New York Times. His thought leadership is also routinely featured in legal compliance publications, including Global Investigations Review, Compliance Week, WorldECR, Energy Intelligence, and Corporate Compliance Insights.
A frequent writer, Jeremy is the sole author of many articles on sanctions published by Dow Jones Risk Journal, Law360, Bloomberg, and WorldECR.
Highlighted Publications
“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.
On Air Interviews
BBC News, interviewed by Chief Presenter Steve Lai on "Newsday," Oct. 22, 2025.
NHK (Japan Broadcasting Corporation), interviewed by Senior Correspondent Takeshi Togawa, May 9, 2025.
“Times Radio,” The Times and The Sunday Times, interviewed by Alexis Conran, March 8, 2025.
Media Quotes
“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.
Highlighted Lectures and Podcasts
- “Unpacking the Lafarge case study: Lessons for multinationals operating in high-risk environments,” Compliance Week, November 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), September 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.
News & Insights For Jeremy P. Paner
View All News & InsightsJeremy Paner Breaks Down Recent OFAC Advisory on Sham Transactions
Jeremy Paner discussed a recent advisory from the Office of Foreign Assets Control (OFAC) that signals U.S. authorities will not overlook efforts by sanctioned individuals or entities to conceal their interests through sham transactions with Global Investigations Review.
Jeremy Paner Analyzes US Treasury’s Anti-Money Laundering Action Against a Swiss Bank
Jeremy Paner analyzed the recent U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) 311 action targeting a Swiss bank with Financial Crime Digest.
Sanctions in a Snap: Developments in Sanctions March 2026
Highlights from March 2026 include unprecedented authorizations involving Russian and Iranian oil, a sanctions advisory providing factors that will lead to aggressive enforcement, and a $1.1 million civil monetary penalty demonstrating the importance of the testing and auditing component of sanctions compliance programs.
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