Seetha Ramachandran
Partner
Seetha Ramachandran is a partner in the Litigation Department.
She is a leading expert in anti-money laundering (AML), Bank Secrecy Act, economic sanctions and asset forfeiture matters. She represents banks, broker dealers, hedge funds, private equity funds, online payment companies, and individual executives and officers, in high stakes and sensitive matters. Her practice focuses on white collar and regulatory enforcement defense, internal investigations, and compliance counseling. In addition to her subject matter expertise, Seetha is an experienced trial and appellate lawyer, having 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.
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Over the past few weeks, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has issued further guidance in the form of Frequently Asked Questions (FAQs) and General Licenses that clarify the terms of the Order and its Chinese Military Sanctions Program. To a large degree, OFAC’s guidance confirms that the agency will interpret … Continue Reading
Ransomware is a Serious and Growing Problem In recent years, Ransomware has evolved from merely encrypting files/disabling networks in solicitation of ransom, to sophisticated attacks that often involve actual data access, theft and sometimes, the threat of publication. These sophisticated malware attacks frequently destroy backups and provide criminals even more leverage over their victims, coercing … Continue Reading
On August 18, 2020, the Financial Crimes Enforcement Network (FinCEN), which is the primary regulator and administrator of the Bank Secrecy Act (BSA), issued a statement on enforcement of the BSA. The requirements of the BSA typically apply to financial institutions, but in certain circumstances the Act applies to nonfinancial businesses and individuals.… Continue Reading
On April 28, 2020, Treasury Secretary Mnuchin announced that companies that received loans of more than $2 million through the Paycheck Protection Program (“PPP”) of the CARES Act will be closely scrutinized. Mr. Mnuchin noted that the Small Business Administration (“SBA”) would audit the business to determine whether the certifications submitted in connection with the … Continue Reading
COVID-19 has created many new concerns for private fund managers; however, managers should be particularly mindful of heightened cybersecurity and fraud risks. With increased numbers of employees teleworking, there are increased vulnerabilities for cybercriminal intrusions creating privacy-related risks for fund portfolio information, LP confidential data, and other sensitive electronically-stored materials.… Continue Reading
The private fund industry is more in the public eye than ever before. Private capital and private markets have experienced massive growth over the last two decades, substantially outpacing the growth of public equity. We have witnessed that trend continue during the past year, and have worked with our clients to navigate the greater uncertainty … Continue Reading
In the ever-evolving and complex world of economic sanctions, voluntary self-disclosure is frequently the best long-term strategy for any company that discovers a violation of a sanctions regime. The more difficult task is to assess the costs and benefits of self-disclosure in cases where the conduct falls into a gray area. We explain the complex … Continue Reading
On August 25, 2019, New York Governor Andrew Cuomo signed New York State Senate Bill S6536 which established a six-year statute of limitations for the prosecution of certain crimes related to fraudulent practices in respect to stocks, bonds and other securities and conducting business in the State of New York. As discussed below, the legislation … Continue Reading
An Overview of OFAC’s Ongoing Guidance: Chinese Military Companies Trading Ban
By Seetha Ramachandran and David W. Heck on Posted in Asset Management, Compliance, Disputes, Enforcement, Securities Law, White Collar
Regulatory Crackdown on Ransomware
By Seetha Ramachandran, Nolan Goldberg and Hena M. Vora on Posted in Compliance, Cybersecurity, Enforcement, Regulation
FinCEN Explains What Guides Its Enforcement Decisions
By Seetha Ramachandran and Hena M. Vora on Posted in Asset Management, Disputes, Enforcement, Regulation, White Collar
Rear View Mirror: Criminal Exposure for Companies that Received PPP Loans Under the CARES Act
By William Komaroff, Seetha Ramachandran and Hadassa Waxman on Posted in Disputes, Examinations, News, Regulation, White Collar
Cybersecurity and Fraud Risks for Fund Managers in the Wake of Coronavirus
By Alexandra V. Bargoot, Margaret A. Dale and Seetha Ramachandran on Posted in News, Private Equity
Top Ten Regulatory and Litigation Risks for Private Funds in 2020
By Margaret A. Dale, Michael R. Hackett, Kirsten E. Lapham, Timothy W. Mungovan, Joshua M. Newville, Seetha Ramachandran, Samuel J. Waldon, Jonathan M. Weiss, Anthony M. Drenzek, James Anderson, Alexandra V. Bargoot, William D. Dalsen, Adam L. Deming, David W. Heck, Brian A. Hooven, Christina H. Kroll, Hena M. Vora and Lucy C. Wolf on Posted in Business Development Companies, Compliance, Disputes, Examinations, Hedge Funds, Mergers & Acquisitions, OCIE, Private Credit, Private Equity, Private Equity Litigation, Regulation, SEC, Securities Law, Venture Capital, White Collar
To Disclose or Not to Disclose: Navigating the Complex Relationship Between Voluntary Self-Disclosure of Sanctions Violations and Enforcement Response
By Seetha Ramachandran and Lucas Kowalczyk on Posted in Compliance, White Collar
New York Establishes Six-Year Statute of Limitation for Prosecution of Claims under the Martin Act
By Anthony M. Drenzek and Seetha Ramachandran on Posted in Disputes, Private Equity Litigation, Regulation, Securities Law
