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JEREMY P. PANER

*** ***** ***, ***** ******, Virginia 22046

703-***-**** adiour@r.postjobfree.com

SUMMARY

Former OFAC official with 13 years of experience handling complex economic sanctions and export controls, anti-bribery and corruption, and anti-money laundering matters. Leverage sophisticated governmental and private sector legal experience to deliver legal and reputational risk analysis for strategic business planning, in addition to regulatory compliance and enforcement mitigation advice. Current and former clients include major multinational companies in a wide range of industries, to include internet-based service providers, a leading defense contractor, manufactures of heavy equipment, automobiles, clothing and apparel, electronics, and medical devices, as well as financial institutions, shippers, and freight forwarders.

Previous member of a New York State Department of Financial Services appointed economic sanctions and anti-money laundering monitorship of a major international financial institution. Cited by the Wall Street Journal, Bloomberg, BBC News, South China Morning Post, Compliance Week, and ACAMS MoneyLaundering.com for insights into sanctions and related anti-money laundering developments. Sole author of many expert assessments on sanctions law published by Bloomberg and Law360.

PROFESSIONAL EXPERIENCE

Of Counsel

Ferrari & Associates, P.C., Washington, DC 05/2019 – present

• Advise and counsel major multinational companies on U.S. sanctions and export control compliance matters

• Regularly provide transactional risk assessments that mitigate sanctions compliance risk arising from proposed sales or dealings

• Assist in the creation of sanctions and export compliance programs and enhance existing programs by drafting policies and procedures

• Provide legal compliance training to major international financial institutions

• Obtain OFAC and BIS licenses for transactions and exports otherwise prohibited by law

• Advocate in front of OFAC on behalf of individuals and entities that may potentially be the target of future sanctions actions

Of Counsel

Holland and Hart LLP, Washington, DC 08/2014 – 05/2019

• Counseled U.S. and foreign businesses in a wide range of industries on compliance with economic sanctions, anti-money laundering, anti-corruption, and export control regulations – representative industries include financial, cryptocurrency, asset management, heavy equipment, automotive, mining, media, entertainment, freight forwarding, electronics, food and beverage, communications and internet services, clothing and apparel, precious stones and gems, and defense 2

• Conducted internal investigations of potential economics sanctions and ITAR violations and prepared voluntary self-disclosures of apparent violations that minimize potential exposure to civil and criminal penalties

• Obtained favorable specific licenses and interpretive guidance on complex areas of regulatory compliance

• Counseled clients on increasing robustness of regulatory compliance programs through written policies and procedures, auditing/testing, and provided sanctions compliance training of personnel

• Regularly provided transactional assessments of potential sanctions compliance risk, including risk arising from market opening into countries under both partial and comprehensive sanctions restrictions

• Assisted clients with sanctions-related submissions to the Securities and Exchange Commission

• Advocated on behalf of individuals and entities seeking removal from OFAC’s Specially Designated Nationals and Blocked Persons List

Associate Director (Global Investigations and Compliance AML and other Financial Services) Navigant Consulting, Washington, DC 07/2013 – 07/2014

• Lead economic sanctions expert on the New York State Department of Financial Services appointed independent monitorship of a major international financial institution, responsible for advising and assessing regulatory consent order-related remedial action planning and execution of its enhanced anti-money laundering and economic sanctions compliance programs o Provided remedial enhancements to the economic sanctions compliance program throughout its worldwide operations

o Enhanced the Know Your Customer (KYC) and Customer Due Diligence (CDD) procedures, and improved the sanctions filter screening and escalation procedures to better manage evolving risk o Enriched the bank’s economic sanctions training and OFAC risk assessment programs

• Served as the firm-wide subject matter expert on all matters involving economic sanctions administered and enforced by OFAC

Sanctions Investigator/Analyst (OFAC and Office of Intelligence and Analysis) United States Department of the Treasury, Washington, DC 09/2007 – 07/2013

• Lead OFAC investigator responsible for sensitive and complex investigations of Iranian-linked financial institutions, responsible for the first use of the Comprehensive Iranian Sanctions and Divestment Act (CISADA) and first designations of an exchange house and trading company, in addition to heading the investigations and drafting the supporting administrative records for all the designations of Iranian-linked financial institutions during a four-year span

• Provided analytical support directly to the highest-ranking government official responsible for economic sanctions and regularly briefed senior-level Treasury officials on terrorism and weapons proliferation finance matters

• Extensive experience with all issues involving OFAC sanctions targeting sanctions evaders, as well as the financing of WMD proliferation, terrorism and narcotics trafficking

• Adjudicated petitions for removal from the List of Specially Designated Nationals and Blocked Persons (SDN List)

SPEAKING ENGAGEMENTS

• World Trade Center Denver – Doing Business in Cuba (July 2017)

• The Finance, Credit & International Business Association – Doing Business in Iran (April 2017) 3

• The Knowledge Group – Opportunities and Legal Risks in the New OFAC Cyber-Related Sanctions Regulations Explored (April 2016)

• American Conference Institute, Economic Sanctions Boot Camp – Practical Implications to Minimize Facilitation Risks When Dealing with a New or Established Client (December 2015)

• American Conference Institute, Foreign Corrupt Practices Act Boot Camp – Complying with New Russian Sanctions and How the 50 Percent Rule Could Affect Your Existing Business Relationships (January 2015)

MEDIA REFERENCES/QUOTES

ACAMS MoneyLaundering.com

“US Treasury Opens New Round of Secondary Sanctions Against Iran's Banks” (10/8/2020)

“Trump Signs Hong Kong Sanctions Bill” (7/15/2020)

“OFAC Stretches Sanctions Authority to Tackle Cyberthieves: Sources” (7/1/2020)

“Treasury Takes Aim at North Korea's Offshore Accounts” (2/12/2020)

“US Treasury Department Finalizes Money Laundering Designation Against Iran” (10/25/2019)

“Miami Attorneys Prepare Helms-Burton Lawsuits Against Three More Banks” (7/12/2019)

“Latest US Designation of Iranian Military Unit Will Challenge Global Banks, Pompeo Says” (4/8/2019)

“OFAC Penalty Highlights Risks of Directing Overseas Subsidiaries, Transactions” (2/5/2019)

“US Prosecutors Move Against Millions of Dollars Linked to North Korea” (11/27/2018)

“OFAC Actions Against US and Iranian Banks Ignite ‘KYCC’ Debate” (10/26/2018)

“US Law Targeting Hezbollah May Increase Bank Due-Diligence Obligations” (10/22/2018)

“US Officials Blacklist Russian Bank, North Korean Banker and Front Companies” (8/3/2018)

“US ‘List of Oligarchs’ Challenges European Banks: Sources” (6/21/2018)

“Iran Central Bank Governor, Iraqi Lender Blacklisted by United States” (5/15/2018)

“Foreign Banks Face Sanctions Minefield After US Exit from Iran Nuclear Deal” (5/8/2018)

“US Sanctions Law Comes With Unprecedented Tripwire for Foreign Banks” (4/19/2018)

“CDD Rule Will Impact More Than AML Compliance: Sources” (4/5/2018)

“Latvian Regulator Will Crack Down on High-Risk Banking Clients: Official” (3/27/2018)

“US Officials Suspected South Korean Banks Aided Iran Before Nuclear Agreement” (2/14/2018)

“FinCEN Blacklists Latvian Lender as Money Laundering Conduit” (2/13/2018)

“Impact of ‘Russian Oligarchs’ List Difficult to Assess: Sources” (1/30/2018)

“Extraterritorial Enforcement Resumes with OFAC Penalty Against African Lender” (1/18/2018)

“In Hunt for North Korean Funds, FinCEN Employs Obscure, Broad Measure” (11/20/2017)

“White House ‘Decertifies’ Nuclear Deal with Iran, Targets Powerful Military Wing” (10/13/2017)

“US Sanctions Evasion Trial May Detail Involvement of Turkish Bank: Sources” (10/12/2017)

“White House Authorizes Secondary Sanctions Against Overseas Banks Tied to North Korea”

(9/21/2017)

“New US Sanctions Against Venezuela Challenge AML Compliance Officers” (9/8/2017)

“US Officials Target Firms in Russia, China and Singapore for Ties to North Korea” (8/22/2017)

“OFAC Fine for Due Diligence in Iran Threatens Legitimate Transactions: Sources” (8/15/2017)

“Sanctions Bill Gives Treasury Greater Oversight of Iranian Guard Transactions” (7/31/2017)

“In Unprecedented Move, FinCEN Blacklists Chinese Bank Tied to North Korea” (6/29/2017)

“China Top Destination for ‘Russian Laundromat’ Funds, Raising AML Concerns” (3/31/2017)

“AML Enforcement Dropped in 2016 Amid Forecasts of Tougher Regulatory Environment” (3/10/2017)

“OFAC Issues Guidance on Compliance Services Relating to U.S. Sanctions Laws” (1/12/2017)

“New York Accuses Chinese Bank of Intentionally Violating AML and Sanctions Rules” (11/4/2016)

“OCC to Pursue Cases Against Wells Fargo Executives” (9/20/2016)

“Iranian Bankers in Contact with American AML Professionals” (8/5/2016)

“U.S. Ends Ban on Financing of Exports to Cuba” (1/26/2016) 4

Compliance Week

“Treasury Amends Russia and Ukraine Sanctions List” (12/23/2015)

“FAQs but Few Answers on Iran Deal Implications” (8/11/2015) Bloomberg

“U.S. Gains in Fight With Chinese Banks Over North Korea Sanctions” (6/25/2019)

“Iran’s Sanctions Evasion Went East After Europe Cracked Down” (2/20/2018) Wall Street Journal, “The Morning Risk Report: OFAC Coordinates Money Laundering Action”

(11/23/2015)

BBC News, “Are the U.S. Treasury Department’s sanctions against Chinese and Hong Kong officials really ‘meaningless’” (8/13/2020)

South China Morning Post, “US sanctions Hong Kong leader Carrie Lam for ‘implementing Beijing’s policies of suppression’” (8/7/2020)

Law Week Colorado, “Holland & Hart Looks to Steer Businesses Through International Trouble”

(6/22/2015)

PUBLICATIONS

• Law360, “What New Syria Sanctions Mean For US Companies” (June 24, 2020)

• Law360, “Next US Move Against Iran Could Block Humanitarian Aid” (August 15, 2019)

• Law360, “Compliance Certifications Jack Up Sanctions Violation Costs” (April 30, 2019)

• Bloomberg Law, “Trump’s Border Emergency Declaration May Undermine Economic Sanctions”

(March 6, 2019)

• Law360, “OFAC Eases Burma Sanctions, But Risks Remain” (June 6, 2016)

• Law360, “Lessons From OFAC’s First Public ‘50 Percent Rule’ Penalty” (February 19, 2016)

• Author of over 50 articles published by Holland and Hart’s tradesanctions.com blog (May 2015 to March 2019)

EDUCATION

The Pennsylvania State University Dickinson School of Law, Carlisle, PA Graduated 05/2004

• Legal researcher for a legal consultant to the National Commission on Terrorist Attacks Upon the United States (9-11 Commission) (01/2003 – 05/2004) James Madison University, Harrisonburg, VA Graduated 12/2000

• Four-year scholarship recipient

MEMBERSHIPS

• District of Columbia Bar

• Virginia State Bar

• American Bar Association

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