Over the past week, the U.S., UK, and EU imposed sweeping sanctions rolled out by the US, in response to Russia’s invasion of Ukraine, outlined here. Also last week, the Department of Justice announced the launch of Task Force KleptoCapture to enforce these sanctions and seize assets belonging to sanctioned individuals and other criminal actors. Attorney General Merrick B. Garland made clear that the U.S. “will leave no stone unturned in our efforts to investigate, arrest, and prosecute those whose criminal acts enable the Russian government to continue this unjust war.”

Task Force KleptoCapture will target the crimes of Russian oligarchs and those who aid or conceal their unlawful conduct. Deputy Attorney General Lisa O. Monaco, whose office will oversee the Task Force, told financial institutions to be on high alert for oligarchs attempting to use the U.S. financial system to hide criminal proceeds and evade sanctions. She emphasized that financial institutions should ensure their customer compliance and anti-money laundering programs are finely tuned to these risks.  In line with the Department’s increased efforts to investigate and prosecute the criminal misuse of cryptocurrencies and digital assets, Task Force KleptoCapture will also target efforts to use cryptocurrency to evade sanctions and launder proceeds of foreign corruption.

The Task Force will include individuals from across the Department and a number of government agencies who are experts in sanctions and export control enforcement, anti-corruption, asset forfeiture, anti-money laundering, tax enforcement, national security investigations, and foreign evidence collection, and will be led by a veteran asset forfeiture and money laundering prosecutor from the Manhattan U.S. attorney’s office.

In the coming days, we anticipate more developments in this area and will continue to update you accordingly.

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Photo of Seetha Ramachandran Seetha Ramachandran

Seetha Ramachandran is a partner in the Litigation Department, and a member of the White Collar and Asset Management Litigation practices. An experienced trial and appellate lawyer, Seetha has conducted 10 criminal jury trials, argued 10 appeals before the U.S. Court of Appeals…

Seetha Ramachandran is a partner in the Litigation Department, and a member of the White Collar and Asset Management Litigation practices. An experienced trial and appellate lawyer, Seetha has conducted 10 criminal jury trials, argued 10 appeals before the U.S. Court of Appeals for the Second Circuit, and handled ancillary civil proceedings in forfeiture cases.

Seetha is a leading expert in anti-money laundering (AML), Bank Secrecy Act, economic sanctions and asset forfeiture matters. Her practice focuses on white collar and regulatory enforcement defense, internal investigations, and compliance counseling. She represents banks, broker dealers, hedge funds, private equity funds, online payment companies, and individual executives and officers in high stakes and sensitive matters. Seetha has deep experience representing institutions and individuals in financial penalty phase of criminal and regulatory matters, and is often retained to litigate forfeiture and restitution claims on behalf of victims and third parties in criminal cases, as well as handling these issues for individual defendants.

Seetha served as a federal prosecutor for nearly 10 years, including as Deputy Chief in the Asset Forfeiture and Money Laundering Section (AFMLS), Criminal Division, U.S. Department of Justice. She was the first head of DOJ’s Money Laundering & Bank Integrity Unit, where she supervised DOJ’s first major AML prosecutions, and oversaw all of the Criminal Division’s AML cases. In that role, Seetha coordinated closely with state and federal banking regulators, including FinCEN, the OCC and the New York State Department of Financial Services, giving her deep experience with how these agencies work together, especially in matters involving civil and criminal liability. Her work developing and charging criminal cases under the Bank Secrecy Act (BSA) formed the model for AML enforcement that regulators and prosecutors follow today.

Seetha also served as an Assistant U.S. Attorney for the Southern District of New York for nearly six years, in the Complex Frauds, Major Crimes and Asset Forfeiture units where she investigated and prosecuted white-collar cases involving a wide range of financial crimes, including bank fraud, mail and wire fraud, tax fraud, money laundering, stolen art and cultural property, and civil and criminal forfeiture cases.

Seetha is a frequent speaker and prolific author on topics including enforcement trends in the financial services industry, OFAC sanctions, effective AML programs and asset forfeiture.

Photo of Hena M. Vora Hena M. Vora

Hena M. Vora is an associate in the Litigation Department and a member of the Asset Management Litigation, Trials, Mass Torts & Product Liability, and Consumer Litigation practices, as well as the Real Estate Litigation group. Her practice encompasses a range of complex…

Hena M. Vora is an associate in the Litigation Department and a member of the Asset Management Litigation, Trials, Mass Torts & Product Liability, and Consumer Litigation practices, as well as the Real Estate Litigation group. Her practice encompasses a range of complex civil and commercial litigation matters, including securities litigation, partnership disputes, and consumer products.

Hena has experience with various stages of litigation, including pitching clients, coordinating discovery, drafting dispositive motions and trial memoranda, handling court conferences, taking and defending depositions, and preparing witnesses for depositions and trial. She also has experience conducting highly sensitive and confidential internal investigations. Hena was part of two trial teams that secured complete defense verdicts on behalf of Monsanto in high-profile product liability actions. She also helped secure a complete dismissal at the trial court and appellate levels on behalf of a prominent private fund client, defending against claims of breach of fiduciary duty, aiding and abetting, and unjust enrichment.

Hena serves as the president of the South Asian Bar Association of New York (SABANY). She also maintains an active pro bono practice and has been awarded for creating a partnership between Proskauer’s Boston office and Minds Matter Boston, through which she helps high school students from low-income backgrounds achieve college readiness and success.

Hena earned her J.D. from Emory University School of Law, where she received the Pro Bono Publico honor and a Transactional Law Certificate. In addition, she was a national competitor on the Moot Court Society and served as president of Emory’s South Asian Law Students Association. While at Emory, Hena served as judicial intern for Judge Denny Chin at the U.S. Court of Appeals for the Second Circuit.

Photo of Amy Gordon Amy Gordon

Amy Gordon is an associate in the Litigation Department and a member of the Mass Torts & Product Liability group. Amy’s practice focuses on a wide range of complex civil and commercial litigation matters, including product liability defense, class action defense, privacy and…

Amy Gordon is an associate in the Litigation Department and a member of the Mass Torts & Product Liability group. Amy’s practice focuses on a wide range of complex civil and commercial litigation matters, including product liability defense, class action defense, privacy and data security, and telecommunications disputes. She is also a member of the litigation team representing the Financial Oversight and Management Board in the Commonwealth of Puerto Rico’s bankruptcy proceedings.

In addition, Amy advises clients across industries on economic sanctions and asset forfeiture related issues.

Amy earned her J.D. from the University of Texas School of Law, where she was a Cybersecurity Graduate Fellow and served as Chief Notes Editor for The Review of Litigation. During law school, Amy interned for the Honorable Nicholas G. Garaufis in the United States District Court for the Eastern District of New York.