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On June 29, the Russian Elites, Proxies, and Oligarchs (REPO) Task Force published a statement on its work in blocking or freezing sanctioned Russian assets. The pressure on businesses to ensure compliance with sanctions and sanctions-adjacent regulations and the cost of the same is significant, but a failure to invest in doing so may have more expensive adverse consequences.

Click here to read the full GT Alert.

Tags: economic sanctions, GT Insight, Russia, Russia Sanctions, Ukraine
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Jo Rickards

Jo Rickards is the Chair of the London office’s White Collar Crime & Investigations Group where she represents a wide range of companies and individuals. Jo is recognised as a leading individual in her practice area advising clients in investigations involving allegations of

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Jo Rickards is the Chair of the London office’s White Collar Crime & Investigations Group where she represents a wide range of companies and individuals. Jo is recognised as a leading individual in her practice area advising clients in investigations involving allegations of corruption, cartels, tax and investment fraud and contentious financial services. She has advised directors and companies in the UK and internationally for over 20 years. She represents companies and individuals investigated by the SFO, FCA, CMA and HMRC and those who are subject to mutual legal assistance requests from criminal authorities abroad.

Jo’s corporate representations range from advising a U.S. parent whose subsidiary agreed to a civil recovery order with the SFO, conducting an independent review for a UK casino chain, advising an online gambling platform in respect of a money laundering investigation and advising a sovereign wealth fund involved in a high profile sanctions matter. She has advised numerous companies on corruption, money laundering and fraud issues. She has acted for individuals in relation to investigations into Unaoil, Patisserie Valerie, Quindell, Rolls Royce, and a multinational tobacco company. She also has deep experience with insider dealing prosecutions and market abuse investigations. She was involved in the Leveson Inquiry into the culture, practices and ethics of the British press and the Manchester Arena Inquest/Inquiry.

She has a particular interest in bribery & corruption, environmental crime and greenwashing and regularly writes and speaks on these subjects.

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Photo of Annabel Thomas Annabel Thomas

Annabel Thomas is an experienced commercial litigator with a strong background in corporate disputes and civil fraud. She represents clients on matters involving asset-tracing and injunctive relief; partnership disputes; competition law; and regulatory/disciplinary litigation. She also handles company and shareholder disputes (including unfair…

Annabel Thomas is an experienced commercial litigator with a strong background in corporate disputes and civil fraud. She represents clients on matters involving asset-tracing and injunctive relief; partnership disputes; competition law; and regulatory/disciplinary litigation. She also handles company and shareholder disputes (including unfair prejudice claims, breach of directors’ duties, JV disputes, LLP disputes and breach of warranty and indemnity claims), as well as insurance disputes (including coverage, subrogated recovery and brokers’ negligence). Annabel’s practice covers litigation in the high court, as well as arbitral proceedings. She is experienced in both defending and bringing claims, often involving multiple jurisdictions and applications for interim relief, including freezing injunctions, search & seizure orders, disclosure orders and security for costs.

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Photo of Bethany Histed Bethany Histed

Bethany Histed focuses her practice on commercial litigation, civil fraud, and complex multi-jurisdictional disputes. She has worked on complex contentious cases of significant value involving allegations of fraud, conspiracy, breach of fiduciary and directors’ duties, breach of contract, claims under the Insolvency Act…

Bethany Histed focuses her practice on commercial litigation, civil fraud, and complex multi-jurisdictional disputes. She has worked on complex contentious cases of significant value involving allegations of fraud, conspiracy, breach of fiduciary and directors’ duties, breach of contract, claims under the Insolvency Act 1986, and unfair prejudice petitions under section 994 of the Companies Act 2006. Bethany also has experience of dealing with asset disclosure and preservation issues.

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Photo of Gavin Costelloe Gavin Costelloe

Gavin Costelloe is a member of Greenberg Traurig’s White Collar Defense & Special Investigations Practice in London. Gavin is a former lawyer and prosecutor for the UK’s Serious Fraud Office (SFO). Gavin advises companies and individuals on internal, government and regulatory investigations and…

Gavin Costelloe is a member of Greenberg Traurig’s White Collar Defense & Special Investigations Practice in London. Gavin is a former lawyer and prosecutor for the UK’s Serious Fraud Office (SFO). Gavin advises companies and individuals on internal, government and regulatory investigations and compliance issues related to the UK Bribery Act, fraud, market manipulation, anti-money laundering, economic sanctions, and other serious and complex cross-jurisdictional matters. Gavin has considerable experience assisting with diligence for mergers, acquisitions, and other investments including in jurisdictions with high corruption risk.

Gavin’s practice is focused on business crime investigation, defence, compliance, and risk mitigation. This includes assisting companies with internal, government, and regulatory investigations (including those conducted by the SFO, Her Majesty’s Revenue & Customs (HMRC), the Crown Prosecution Service (CPS) and the Competition and Markets Authority (CMA)), individual defence for senior executives and compliance professionals, and devising and implementing internal training and compliance progammes.

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Photo of Kara M. Bombach Kara M. Bombach

Kara Bombach assists companies and organizations to lawfully export goods, technology and services around the globe. She places emphasis on helping clients achieve practical, workable solutions to complex regulatory situations arising under anti-corruption and anti-bribery measures (U.S. Foreign Corrupt Practices Act (FCPA) and

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Kara Bombach assists companies and organizations to lawfully export goods, technology and services around the globe. She places emphasis on helping clients achieve practical, workable solutions to complex regulatory situations arising under anti-corruption and anti-bribery measures (U.S. Foreign Corrupt Practices Act (FCPA) and OECD Convention), export control laws (EAR and ITAR), anti-boycott laws, and special sanctions (embargoes) maintained by the U.S. government (OFAC and other agencies) against various countries (including Iran, Cuba and Russia), entities and individuals. In cases of foreign investment in the United States, Kara advises on the Exon-Florio provisions relating to U.S. national security concerns. She represents companies before the Committee on Foreign Investment in the United States (CFIUS), and also assists clients in mitigating foreign ownership, control or influence (FOCI) as may be required by CFIUS or U.S. national industrial security regulations.

Kara regularly represents clients in matters before U.S. government agencies, including the U.S. Departments of Commerce, State, Treasury and Defense. Kara has significant experience representing individuals and entities before OFAC in delisting matters and challenges to OFAC sanctions designations.

She advises national and multi-national companies (including Fortune® 5) on best practices in the development and delivery of compliance policies and procedures, training, and risk assessments, as well as executing cross-border export, sanctions and anti-corruption due diligence in mergers and acquisitions, targeted internal risk assessments, and compliance investigations.

Kara also counsels international not-for-profit and relief/aid organizations on best practices in economic sanctions, trade, and anti-corruption compliance issues that arise in their global operations, frequently in challenging and austere environments. She has provided legal services to organizations such as Save the Children (US), ONE Campaign, Mercy Corps, the International Committee of the Red Cross, Not on Our Watch/The Sentry, and The Enough Project.

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Photo of Kyle R. Freeny Kyle R. Freeny

Kyle R. Freeny, a skilled trial attorney and former federal prosecutor for the Special Counsel’s Office and the Department of Justice’s Money Laundering and Asset Recovery Section (MLARS), draws on more than a dozen years of high-profile experience in the federal government to

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Kyle R. Freeny, a skilled trial attorney and former federal prosecutor for the Special Counsel’s Office and the Department of Justice’s Money Laundering and Asset Recovery Section (MLARS), draws on more than a dozen years of high-profile experience in the federal government to help clients navigate sensitive government and internal investigations, criminal and civil enforcement matters, and related complex litigation. She has particular experience in matters involving complex financial crime, cross-border investigations, anti-money laundering, anti-corruption, economic sanctions, asset forfeiture, and affirmative challenges to federal agency action.

While at the Department of Justice, Kyle also played a key role in major international money laundering and corruption matters, including important matters involving the Bank Secrecy Act (BSA) and Foreign Corrupt Practices Act (FCPA). Kyle also has considerable experience handling sensitive and complex cross-border issues in transnational financial cases, and she was responsible for the largest civil asset forfeiture recovery in DOJ history.

Kyle uses this deep experience in federal law enforcement to counsel clients facing scrutiny from DOJ, the Securities and Exchange Commission (SEC), the Financial Crimes Enforcement Network (FinCEN), and other law enforcement and financial regulatory agencies. Kyle conducts internal investigations on a range of issues and advises clients on a wide array of anti-money laundering, anti-corruption, and other compliance issues.

Kyle also helps clients develop and litigate challenges to federal regulations, policies, and agency decisions across a range of industries, drawing on her years of prior experience at DOJ representing a cross-section of federal agencies —from the Office of Foreign Assets Control (OFAC) to the Department of Energy to the Department of State and various intelligence agencies—in high-profile litigation. She has appeared before federal trial courts across the country.

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