Kurt represents clients in connection with complex regulatory and transactional matters. Kurt assists clients to identify and mitigate corruption, money laundering, and sanctions risks, and he has served as the lead associate on dozens of international risk assessments. Kurt regularly assists in developing effective, risk-based compliance programs for asset managers and companies with global operations. Kurt also advises clients in connection with the Committee on Foreign Investment in the United States (CFIUS) review process.

Kurt attended the University of Chicago Law School where he was a member of The University of Chicago Law Review. Kurt also spent time providing legal defense services to at-risk Chicago youth through the University of Chicago’s Criminal and Juvenile Justice Project.


  • Conducted anti-corruption and economic sanctions due diligence in connection with hundreds of cross-border transactions.
  • Routinely assist U.S. asset managers to negotiate anti-money laundering and sanctions issues in subscription and distribution agreements.
  • Assist asset managers to develop or enhance their U.S. anti-money laundering and economic sanctions compliance programs.
  • Negotiated a global anti-money laundering compliance framework with a leading financial technology platform on behalf of an investment management client.
  • Represented U.S. embedded system and cloud software company in securing CFIUS pre-clearance for $3.5 billion acquisition by Irish technology company.
  • Represented UK investor in securing CFIUS pre-clearance for investment in provider of surveillance technology to the homeland security and defense markets.
  • Represented Asia-based investor in securing CFIUS pre-clearance for investment in U.S. data center company.
  • Represented U.S. dental and vision insurance company in securing CFIUS pre-clearance for acquisition by Canadian firm.
  • Represent corporate and private equity clients in connection with CFIUS analyses.
  • Develop anti-corruption and sanctions compliance programs for clients with operations in high-risk countries.
  • Completed a full-time secondment at a major private equity firm, assisting with anti-corruption and sanctions compliance.
  • Represented multinational life sciences company in connection with potential violations of Russia/Ukraine and Crimea sanctions.
  • Represented multiple companies in connection with global anti-corruption and sanctions focused risk assessments.
  • Represented multinational life sciences company in connection with multiple internal investigations concerning allegations of bribery and bid-rigging in China.
  • Represented multinational life sciences company in connection with internal investigation concerning instances of possible bribery in Southeast Asia.
  • Obtained asylum for Tajik woman persecuted on account of her non-conformity with prevailing social, political, and religious norms and who feared future persecution on account of her sexual orientation.

Areas of Practice