Understanding OFAC Issues in 2012

Laura Yovanoff is a Sanctions Compliance Officer with the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). Since 2010, Laura has worked in a variety of capacities for OFAC. She manages a large portfolio of financial institutions for which she investigates and enforces sanctions violations. Laura’s diversified portfolio includes large, sophisticated financial institutions, credit unions, and U.S. branches of foreign banks. In addition to enforcement matters, Laura routinely evaluates financial institutions’ compliance programs to identify areas of improvement.

On a daily basis, Laura provides guidance to financial institutions, money service businesses, law enforcement, the legal community, and individuals from around the world on a wide range of complex sanctions issues, particularly Iran, Libya and the new Syrian sanctions. Laura is a regular speaker at other government agency financial investigations trainings, including the Department of Homeland Security and the Federal Financial Institutions Examination Council. Her outreach events focus on the intricacies and nuances of OFAC’s sanctions programs, and the importance of implementing and maintaining a strong compliance program.

Prior to joining OFAC, Laura worked for a non-profit advocacy organization, and in the United States Senate, while simultaneously working towards her Master’s in Political Science at American University. Laura also has several years of experience in the mortgage and title insurance industry, and provided financial analysis services to a large telecommunications company.

Michael Zytnick is a Compliance Officer for the Office of Foreign Assets Control, working within the organization’s Sanctions Compliance and Evaluation division. Based in Washington, he works closely with global banking and financial services firms on risk identification and mitigation, transaction surveillance, and the development of compliance programs. In this role, he frequently provides guidance on matters related to correspondent banking, securities, and trade finance. Most recently, Michael has served on a U.S. Treasury coordination team responsible for addressing sanctions concerns in situations of kidnap and ransom. He is also a member of the Bank Secrecy Act Advisory Group subcommittees on cross-border funds transfers and non-bank financial institutions, which present policy recommendations to the Treasury Secretary on making the U.S. financial system more resistant to fraud, money laundering and terrorist financing. 

Michael has participated in interagency working groups on the implementation of new sanctions programs and on the tracking of blocked assets under U.S. jurisdiction. Additionally, he is responsible for handling complex financial sector enforcement cases related to possible violations of U.S. economic sanctions laws. Michael is also actively involved in conducting training and providing outreach to banking and international trade professionals. 

Prior to joining OFAC, Michael worked on precedent-setting litigation arising from monopolization and merger disputes. He received his B.B.A., summa cum laude, from the George Washington University, where he was honored with the Distinguished Scholar Award.

Maureen regularly advises on compliance with the USA PATRIOT Act, Bank Secrecy Act and Office of Foreign Assets Control requirements; federal/state law preemption issues; privacy, data protection and security matters; Fair Credit Reporting Act compliance; Foreign Corrupt Practices Act matters; Right to Financial Privacy and Freedom of Information Act requests; Regulation E, payment card and stored value card issues; e-commerce and E-Sign compliance; a wide variety of cyberlaw issues such as information security breach, anti-spam compliance and identity theft matters; and protection of critical infrastructure information and other Homeland Security Issues. She is also Bingham’s privacy administrator. 

With respect to commercial technology matters, Maureen structures and negotiates a wide variety of commercial technology agreements, including licensing and development agreements, technology acquisitions, strategic alliances, and major outsourcing arrangements. She also advises on both domestic and offshore outsourcing agreements and vendor management issues, conducts Web site reviews, and advises on e-commerce matters. 

Before joining Bingham in 2003, Maureen was assistant general counsel in Bank of America’s Legal Department in the Regulatory and Corporate Services Group. During her 10-year tenure with Bank of America, she worked on many of Bank of America’s major acquisitions, strategic initiatives, regulatory matters and compliance initiatives, including community development programs and internal investigations. She represented Bank of America in numerous major technology transactions. She also served as Bank of America’s lead in-house counsel in its acquisition of a private telecommunications network with multiple carriers for interstate and intrastate services.

Jim Slear is a partner in the International Trade practice. Jim advises domestic, foreign and multinational clients in a wide array of industries, including aerospace, biomedicine, defense, financial services, insurance, Internet services, manufacturing, semiconductor and telecommunications. He focuses his practice on international trade compliance and enforcement, including the economic and trade sanctions administered by the Office of Foreign Assets Control (OFAC), the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR) and the Foreign Corrupt Practices Act (FCPA). He also advises clients regarding matters before the Committee on Foreign Investment in the United States (CFIUS). 

Jim has more than 25 years of experience conducting investigations. He has conducted internal investigations for numerous clients in international trade and other matters--such as antitrust and securities--both domestically and abroad, including Europe, the Middle East, Japan, the People's Republic of China and Malaysia. 

Prior to entering private practice, Jim was a Judge Advocate with the U.S. Air Force. During his military career, he became an accomplished trial lawyer, serving as the Air Force's Chief Trial Counsel in Asia and later as a Federal Court Trial Attorney for the Air Force's Commercial Litigation Division. He reached the rank of Lieutenant Colonel in the U.S. Air Force Reserves following 16 years on active duty. After leaving active duty in 2000, Jim spent more than ten years at the DC office of a global law firm where he advised clients on international trade compliance and enforcement matters. He also argued motions before federal and state courts and prevailed on appeal before two state supreme courts. 

Service Areas
International Commerce

Licensure
District of Columbia
United States Court of Federal Claims
United States Court of Appeals for the Federal Circuit

Education
Georgetown University
- J.D., magna cum laude (1992)
Oregon State University
- M.S. (1987)
University of Evansville
- B.A. (1979)

Meredith Rathbone is a Partner with the law firm of Steptoe & Johnson LLP in Washington, D.C., where she counsels clients on international regulatory compliance matters. Ms. Rathbone advises clients on compliance with export controls and economic sanctions regulations, including the establishment of compliance and audit programs, undertaking commodity classification and jurisdiction assessments, seeking licenses, and obtaining advisory opinions from the relevant regulatory agencies. Ms. Rathbone advises and assists clients in undertaking internal investigations relating to compliance with economic sanctions and export controls regulations, and on making voluntary disclosures to U.S. government agencies. 

Ms. Rathbone writes and speaks regularly on international regulatory compliance matters. She is a Vice Chair of the American Bar Association, Section of International Law’s Export Controls and Economic Sanctions Committee. In addition, she has taught courses relating to international law as an adjunct professor at Georgetown University