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Attorneys Susan Kovarovics, Andrey Spektor, and Brett Orren authored an article published Dec. 17 on The article discusses the recent scrutiny banks are facing from regulators and overlapping mandates impacting those financial institutions. Two opinions mentioned are those from the second Circuit on Kaplan v. Lebanese Canadian Bank and United States v. Turkiye Halk Bankasi A.S. (Halkbank). These decisions strip protection from foreign banks, open them to private lawsuits, and impose unprecedented due diligence requirements.

Last year, Congress passed the most drastic anti-money laundering (AML) reform in the last two decades, the Anti-Money Laundering Act of 2020. The law promises millions to potential whistleblowers to report AML and Bank Secrecy Act violations, increases criminal penalties, and—most notably—extends the United States’ already broad reach into other countries by allowing prosecutors to subpoena foreign banks for information on foreign accounts.

Susan Kovarovics is the Partner in Charge of the D.C. office and leads the firm’s global international trade practice. She counsels U.S. and non-U.S. private and publicly held companies through sanctions-related compliance issues. 

Andrey Spektor is a partner in the firm’s New York office. He is a former federal prosecutor in New York who has routinely appeared before the Second Circuit. 

Brett Orren is a litigation associate at the firm, with particular experience in sanctions work.

This document provides a general summary and is for information/educational purposes only. It is not intended to be comprehensive, nor does it constitute legal advice. Specific legal advice should always be sought before taking or refraining from taking any action.