Allen & Overy partner Maura Rezendes featured as a Distinguished Adviser by Financier Worldwide
11 January 2022
A&O’s Maura Rezendes has been featured as a Distinguished Adviser by Financier Worldwide in their Power Players International Trade & Sanctions 2021 publication. Read the full article and interview below:
Maura Rezendes advises clients—financial institutions and corporates alike—on a wide range of matters implicating economic sanctions administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), foreign investment in the U.S. regulated by the Committee on Foreign Investment in the United States (CFIUS), export controls, anti-corruption and money laundering. Her practice is multidisciplinary and includes regulatory compliance advice and counselling, transactional support, investigations and enforcement, as well as frequent agency-facing work including before OFAC, CFIUS and the Directorate of Defense Trade Controls (DDTC).
Q&A with Maura Rezendes
Could you provide an insight into how you approach your work? What drives and motivates you?
In a word, with gratitude. Working in a firm and developing a practice with such interesting clients, with interesting issues and questions, drives and motivates me to position our team to be able to provide the very highest level of advice and counselling to our clients across the board, without exception. We work in a rapidly evolving, dynamic area of the law, making each new day, new matter, and new client ever more exciting.
Looking back, have you fulfilled the ambitions and aspirations you set for yourself early in your career?
I feel that I am on the way to fulfilling the ambitions and aspirations I set for myself. I started my career in private practice, then made a strategic decision to go to the government—the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC)—at a time when it was crucial to get an understanding of the inner workings and thinking of the agency that is the primary implementer and enforcer of U.S. economic sanctions. I went to the government with an eye toward coming back to private practice armed with the knowledge and experience I gained at OFAC to better advise and help my clients. This is now playing out in real-time, and it could not be a better time given the prevalence and importance of sanctions globally.
Reflecting on your area of expertise, how do you see this sphere of the market shaping up over the coming months? Are any exciting trends or developments on the horizon?
The breadth and depth of U.S. sanctions has substantially evolved over the course of my career and continues to do so. Interestingly, sanctions, in recent years, have been more surgical in nature, and I believe we are less likely to see comprehensive sanctions programmes such as the U.S. programme targeting Iran or Cuba, going forward. Rather, sanctions are more tailored and, perhaps counterintuitively, harder to comply with. Sanctions compliance and risk assessment is now highly nuanced given that much activity with certain kinds of sanctions targets remains lawful, while certain activity is prohibited or otherwise gives rise to sanctions risk. This trend will likely continue with broad-based sanctions authorities coming out of the U.S. that can be deployed on an incremental basis in response to escalating geopolitical landscapes.
- Advised a cryptocurrency trading platform in a U.S. government investigation involving multiple agencies, on possible breaches of and compliance with U.S. sanctions regulations.
- Advised a multinational corporate on navigating its business operations in Belarus following escalation of U.S. sanctions targeting various sectors of the Belarus economy and persons and entities connected to the Belarus government, including making an application to OFAC for a determination around whether certain continued activity would be considered sanctionable.
- Advised a UK-based private equity fund on compliance with U.S. sanctions following the imposition of sanctions on its co-investor in a portfolio company, which rendered the portfolio company also the target of blocking sanctions on the basis of OFAC's 50%; providing strategic advice and counsel on a planned exit from the investment, including seeking a licence from OFAC to take the necessary steps to achieve the exit.
This article has been reproduced with approval from Financier Worldwide Ltd.