Dealing with Sanctions and Anti-Corruption Compliance Issues After an Internal Audit: Best Practices in France, the United Kingdom and the United States

Raminta Dereskeviciute focuses her practice on product compliance, trade regulation (sanctions and export controls) and ESG. She has significant experience in advising on EU and UK chemical legislation (REACH), product safety and liability rules and frequently represents clients before the European Chemicals Agency Board of Appeal. Raminta also advises businesses on the implications Brexit has in relation to a range of regulatory compliance issues.

Raminta counsels clients on the EU and the UK sanctions regimes and export controls, including in higher risk jurisdictions such as Russia and Iran. Her experience covers the review and design of compliance programs, including giving training to client teams on controlled goods, prohibited jurisdictions, persons and activities. Raminta assists companies in liaising with regulators when assessing whether their activities are in breach of EU or UK sanctions regimes, or whether authorisations / licenses from the national authorities are appropriate. Raminta has participated as a chair and speaker on sanctions related panels at the Cambridge International Symposium on Economic Crime.

Raminta has a peerless grasp of EU chemicals, metals and mining policy, including conflict minerals legislation and the issues surrounding ethical supply chain management for these industries. She also advises companies and trade associations on the European Commission’s Chemical Strategy for Sustainability, building upon her long standing experience on legislative developments in the field of chemicals (REACH, CLP, GHS, WFD, Seveso III, RoHS, WEEE and others).  Raminta devises compliance and crisis management programs and assists global industrial products manufacturers with international product recalls. Raminta featured  in Chemical Watch, Bloomberg Environment and numerous other publications discussing EU chemicals and environmental policy, industry compliance and Member State enforcement as well as implications that Brexit will have on various stakeholders. She is a contributor to the most comprehensive book published on REACH, “Best Practice Guide to Regulation (EC) No 1907/2006”, by Beck/Hart.

Nicolette Kost De Sèvres focuses her practice on global investigations, compliance and regulatory enforcement matters. A former financial regulator and general counsel of a large, listed company, she has over 24 years of experience in compliance, white-collar crime and financial regulation. Nicolette serves as co-head of McDermott Will & Schulte’s global investigations and compliance practice.

Nicolette has practiced in Paris, London, Sydney, Washington, DC, and Montreal, including at the New York Stock Exchange in Paris (NYSE Euronext) and the Royal Bank of Scotland in London. She also served as chief of staff and advisor to the president of the Financial Markets Authority in Canada under two different presidents.

Nicolette has a wealth of experience in anti-corruption and anti-money laundering (AML) compliance both in Europe and globally. She handles corporate and regulatory investigations, risk assessments, and due diligence compliance, including Know Your Client (KYC) regulations. Nicolette also represents clients before enforcement agencies and regulators in Europe, Canada and the United States, such as the new French Anti-Corruption Agency (AFA) and assists them in compliance, investigations and regulatory matters related to regulators such as ESMA the AMF, ACPR, CFTC, SEC, the World Bank and other multilateral banks.

Nicolette advises financial institutions and global and local companies on preventive measures. She is a sought-after advisor in complex white-collar crime matters, building and strengthening local and global compliance programs, preparing or conducting risk assessments and mapping, whistleblowing systems, compliance programs, World Bank Integrity Guidelines, the French Loi Sapin II, Loi sur le devoir de vigilance, FCPA, UKBA, EU Directives relating to whistleblower protection, ESG reporting, EU financial regulation (including MIFID, EMIR, AIFMD, BASEL, BRDD, AML, PDS2, SEPA) and FinTech regulation. Additionally, she has a special insight on the military and defense sectors in the United States and France.

A known thought leader in the global market, Nicolette is a sought-after writer and speaker on compliance, enforcement, business ethics, international financial markets and the effects of regulation on financial systemic risk, derivatives, high-frequency trading and the legal framework of European financial markets.

She is the author of the book International Economic Law, numerous articles in compliance and investigations and one of the first articles on DLT, “Blockchain Revolution: An Analysis of Regulation and Technology Related to Distributed Ledger Technologies.” She teaches compliance, investigations and FinTech.

Sabine Naugès counsels clients on all aspects of public law, including administrative and regulatory, competition and constitutional law. Among other high-profile clients, Sabine has advised telecommunications companies France Télécom and Orange on regulatory matters in cases before administrative and commercial courts, and before EU and French competition authorities. She also regularly represents major companies with interests in a wide range of industries, including aerospace, energy, oil and gas, and public health care, before the French government and in litigation, in a range of regulatory and administrative matters.

Sabine has taught administrative, regulatory and energy law at the University of Paris I Panthéon-Sorbonne, and she teaches petroleum and mining law in the framework of the energy law program of the same university. Sabine has served for three years as in-house counsel in a major, publicly owned company.

Sabine has written numerous articles for French administrative law reviews. She co-authored the Concurrence, Régulation et Secteur Public (Antitrust, Regulation and Public Sector) chapter of the Contrats, Concurrences, Consommation (Contracts, Antitrust and Consumption) Law Review.