From Compliance to Crisis: The Hidden Legal Risks in Maritime Sanctions Enforcement.

David Tannenbaum started his career in sanctions compliance while serving at OFAC, the US agency in charge of administering economic sanctions. In his capacity, he oversaw the analysis of blocked and rejected transactions and provided sanctions to some of the world’s largest financial institutions, Fortune 500 companies, and law firms.

After joining the private sector in 2013, David created Blackstone Compliance Services, a company specializing in sanctions compliance. As the director of Blackstone, he has led sanctions testing for three major monitorships on behalf of the US Department of Justice, Federal Reserve Board, New York Department of Financial Services, and foreign regulators such as the United Kingdom’s FCA and France’s APCR.

His experience goes beyond representing and responding to regulators and law enforcement authorities. He frequently works with some of the largest financial institutions and Fortune 500 companies to develop compliance programs and implement technology to detect sanctions evasion and money laundering. He has done significant work for half of the global Top-10 financial institutions. He has conducted many complex investigations spanning multiple jurisdictions where he untangled complicated sanctions networks used by North Korea, Iran, Syria, and Russia.

Mr. Tannenbaum graduated magna cum laude with an MBA and a Masters in United States Foreign Policy from American University. He also holds a bachelor’s degree in international studies from American University.

Brian Maloney is a partner in the Litigation & Investigations group at Seward & Kissel LLP. Brian is a commercial litigator with significant experience across a wide range of sectors, including banking, maritime, and securities. He also represents clients in matters involving civil and criminal enforcement inquiries and regulatory investigations. He frequently acts in complex commercial disputes or regulatory investigations involving cross-border or other parallel proceedings and issues of foreign law. He has written and spoken extensively in connection with his shipping litigation and sanctions work and he regularly advises clients on matters relating to economic sanctions administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), as well as inbound and outbound investment controls. Brian was named a “2021 Litigation Trailblazer” by the National Law Journal, one of only 25 attorneys recognized nationally. He has also been recognized by the Legal 500 as a “Next Generation Partner” and by Chambers & Partners USA for his work in shipping litigation and regulation. In 2022 he was elected a Fellow of the American Bar Foundation. Brian received an A.B. degree (cum laude) from Dartmouth College and a J.D. degree (cum laude) from Boston College Law School. He is a member of the Board of Directors of New York Maritime Inc. (NYMAR), sits on the New York City Bar Association’s Admiralty Committee; and is a member of the Maritime Law Association of the United States, as well as the ABA, the New York County Lawyers’ Association and the Dartmouth Lawyers’ Association.

Marc J. Armas is a partner at Avelino Law, LLP and serves as chair of its Litigation Practice Group. A graduate of the United States Coast Guard Academy and Rutgers School of Law, Marc brings together extensive litigation experience, leadership, and a distinguished military background to deliver strategic solutions to complex legal and compliance challenges.

He has a strong track record in white-collar criminal defense, crisis management, and internal investigations. His experience spans high-stakes matters involving the Foreign Corrupt Practices Act (FCPA), False Claims Act (FCA), Bank Secrecy Act (BSA), and issues such as insider trading, digital currency theft, cyber breach investigations, money laundering, sanctions violations, financial fraud, and market manipulation.

Marc previously served as an Assistant U.S. Attorney in the District of New Jersey and as an Assistant District Attorney in Queens County, New York. His military service includes leading a maritime counterterrorism team in the U.S. Coast Guard, serving aboard a high-endurance cutter conducting counternarcotics operations, and being cross-designated as a Reserve Judge Advocate General (JAG) officer.

Recognized for his leadership in high-profile regulatory and compliance initiatives, Marc has played a key role in monitorships and sanctions compliance reviews for major financial institutions under regulatory scrutiny. He has tested and implemented compliance frameworks, led cross-functional teams, and provided strategic guidance on high-risk transactions. His expertise also includes navigating FINRA/SEC regulations and advising clients in the banking and advisory sectors on best practices.

Marc is a frequent speaker and contributor on topics including enforcement policies, corporate investigations, and cybersecurity compliance. He is also an active member of several professional and community organizations, including the Maritime Law Association of the United States and the New York City Bar Association Admiralty Committee.

Ivy Llena has over 14 years of experience in the learning and development field, providing capacity-building and professional development programs for corporate and social service agencies in the US and the Philippines.

Before joining ACSS, she was a program director at a non-profit organization in the Philippines, where she co-designed and co-implemented economic empowerment programs and services for survivors of human trafficking and their families. Ivy also served at the Social Policy Institute at Washington University in St. Louis, where she led and contributed to inclusive economic growth initiatives.