Brendan Hanifin provides clients with comprehensive regulatory and transactional counseling across a range of international risks, including foreign direct investment regulations, economic sanctions, anti-money laundering laws, and anti-corruption laws. Clients value Brendan’s breadth of regulatory knowledge, transactional proficiency, and ability to forge practical solutions tailored to their business and strategic goals.
Brendan represents clients in national security reviews before the Committee on Foreign Investment in the United States (CFIUS), including reviews of non-notified transactions and negotiation of national security agreements. He routinely provides CFIUS-related advice and counseling to private equity sponsors, venture capital firms, sovereign wealth funds, and U.S. businesses throughout all stages of the investment life cycle.
Drawing on his years of experience conducting international risk due diligence, clients rely on Brendan to navigate their most complex cross-border transactions. In this capacity, Brendan has evaluated hundreds of companies’ international risk compliance programs, understanding that there is no one-size-fits-all solution to managing international risks. He leverages this experience to help clients across a broad range of industries perform complex risk assessments and develop (or enhance) effective, risk-based compliance programs. Brendan has particular experience helping U.S. investment managers develop risk-based anti-money laundering and economic sanctions compliance programs.
Brendan also represents clients in multijurisdictional internal investigations and government enforcement actions. He has assisted numerous clients to prepare and resolve disclosures to the Office of Foreign Assets Control (OFAC), the Bureau of Industry and Security (BIS), the Directorate of Defense Trade Controls (DDTC), the Department of Justice (DOJ), and the Securities and Exchange Commission (SEC).
A former member of Law360’s International Trade Editorial Advisory Board, Brendan publishes regularly on international risk-related topics.
- Represented U.S. embedded system and cloud software company in securing CFIUS pre-clearance for $3.5 billion acquisition by global 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.
- Represented Asia-based investor in securing CFIUS clearance for investment in U.S. enterprise software company.
- Represented Asia-based investor in CFIUS review of investment in advanced information technology company.
- Represented Asia-based investor in securing CFIUS clearance for investment in U.S. logistics company and government contractor.
- Represented venture capital firm in securing CFIUS pre-clearance for investment in U.S. artificial intelligence and machine learning company.
- Represented venture capital firm in CFIUS review of investment in U.S. cybersecurity company.
- 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.
- 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.
- Represented leading asset managers and investment firms in internal reviews of, and responses to, allegations of anti-money laundering program deficiencies.
- Represented leading asset manager in a product-focused anti-money laundering risk assessment.
- Represented real estate investment firm in connection with acquisition of a commercial property implicated in a federal money laundering investigation.
- Represented investment manager in negotiation of a global anti-money laundering compliance framework with a leading financial technology platform.
- Represented private equity firm in connection with acquisition of retail business embroiled in a corruption and money laundering investigation.
- 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.
- 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.