Brendan C. Hanifin

Counsel

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  • JD, magna cum laude, Fordham University School of Law, 2011; Order of the Coif; Fordham Law Review
  • BA, Williams College, 2008

Qualifications

  • Illinois, 2015
  • New York, 2012
  • Massachusetts, 2011

Court Admissions

  • U.S. Court of Appeals for the Seventh Circuit, 2017
  • U.S. District Court for the Northern District of Illinois, 2015
  • Member, International Trade Editorial Advisory Board, Law360 (2018-2020)

Brendan C. Hanifin

Counsel

Brendan Hanifin advises clients on international risk compliance matters, as well as the Committee on Foreign Investment in the United States (CFIUS) review process.

Brendan has represented clients in the energy, financial, healthcare, investment management, life sciences, manufacturing, and transportation and logistics industries in internal and governmental investigations of potential violations of economic sanctions, export control laws, customs regulations, anti-corruption laws, and anti-boycott laws. He regularly advises private equity sponsors and venture capital firms on economic sanctions, money laundering, export control, and corruption risks related to international transactions and investments. Brendan also represents clients in national security reviews before CFIUS, and he assists U.S. and non-U.S. clients to manage CFIUS risk in connection with fundraising and investment activities.

Brendan has assisted clients across a broad range of industries to develop or enhance their compliance programs. He has particular experience assisting U.S. investment advisors to develop risk-based anti-money laundering and economic sanctions compliance programs.

A member of Law360’s International Trade Editorial Advisory Board, Brendan writes frequently on CFIUS, economic sanctions, and other international risk compliance matters. Brendan’s pro bono practice has included the successful representation of numerous clients with criminal records in post-conviction relief proceedings in federal and state court, as well as administrative hearings.

Experience

Committee on Foreign Investment in the United States (CFIUS)

  • Represented Asia-based investor in securing CFIUS pre-clearance for investment in U.S. travel company.  
  • Represented U.S. insurance company in securing CFIUS pre-clearance for acquisition by Canadian firm.
  • Represented German company in securing CFIUS pre-clearance for acquisition of U.S. lubricants company.
  • Represented German company in securing CFIUS pre-clearance for acquisition of U.S. metals company.
  • Represented Hong Kong-based technology company in securing CFIUS pre-clearance for acquisition of U.S. semiconductor business. 

Economic Sanctions

  • Represented international transport and customs brokerage company in investigations of potential violations of economic sanctions involving subsidiaries in Asia, North America, Europe, and the Middle East; assisted client to prepare and resolve multiple voluntary disclosures to OFAC.
  • Represented life sciences company in investigation of potential violations of the Ukraine/Russia and Crimea sanctions; assisted company to prepare and resolve disclosures to U.S. regulators.
  • Represented private equity firm in review and voluntary self-disclosure of possible violations of U.S. economic sanctions related to a potentially sanctioned investor.    
  • Represented nonprofit academic research institution in review of U.S. sanctions violations committed by university researcher in connection with multi-center research study; assisted client to prepare and resolve voluntary disclosure to OFAC.
  • Represented German company in obtaining specific license from OFAC authorizing continued wind-down activities in Iran following the revocation of General License H.  

Customs/Export Controls

  • Represented customs brokerage company in major CBP enforcement action related to purported violations of U.S. customs regulations.
  • Represented life sciences company in investigation of potential violations of the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), and Foreign Trade Regulations (FTR); assisted client to prepare and resolve disclosures to U.S. regulators.
  • Represented energy company in investigations of possible violations of U.S. export control and anti-boycott laws; assisted client to make and resolve disclosures to U.S. regulators.
  • Represented oil and gas company in global trade compliance diagnostic review; assisted client to enhance controls related to compliance with export control laws, economic sanctions, and anti-boycott laws.
  • Represented industrial equipment and technology manufacturer in internal investigation of possible violations of customs, export control, and anti-boycott laws involving conduct across Asia, Latin America, and the Middle East.
  • Represented retail company in response to CBP inquiry concerning Chinese manufacturing operations.  

Anti-Corruption

  • Represented medical device company in a wide-ranging DOJ and SEC corruption investigation (involving countries across Asia, Europe, and Latin America) and multi-year corporate compliance monitorship.
  • Represented life sciences company in multiple internal investigations into allegations of corruption in Asian markets.
  • Represented a U.S.-based drug manufacturer in internal investigation into allegations of product diversion and improper payments to healthcare providers.

Publications

Presentations

  • Presenter, “US Sanctions and New Anti-Money Laundering Legislation: What It Means for the Art Market,” Bar Association of San Francisco (February 2020)
  • Presenter, “Economic Sanctions & Export Control Risks for the Health Care & Life Sciences Industries,” Ropes & Gray Webinar (November 2019)
  • Presenter, “International Risks Posed By Digital Currencies,” Ropes & Gray Webinar (April 2018)
  • Presenter, “International Risk Developments for Oil & Gas Companies,” Bloomberg BNA (February 2017)
  • JD, magna cum laude, Fordham University School of Law, 2011; Order of the Coif; Fordham Law Review
  • BA, Williams College, 2008
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