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Jeremy P. Paner
Principal
Jeremy P. Paner counsels and represents clients in a wide range of industries on compliance with trade sanctions and national security-related matters, with particular focus on US economic sanctions. Jeremy draws on his experience as a former Office of Foreign Assets Control (OFAC) official, including in his representations of clients seeking removal of sanctions. Jeremy has handled hundreds of requests for rescission of sanctions designations for both the US government and on behalf of clients in private practice.
Jeremy is a principal in the International Trade Practice Group, who leverages his sophisticated governmental and private sector experience to deliver legal and reputational risk analysis for strategic business planning, in addition to regulatory compliance and enforcement mitigation advice.
Jeremy has significant experience advising clients in industries including financial, cryptocurrency, asset management, heavy equipment, automotive, mining, media, entertainment, freight forwarding, electronics, food and beverage, communications and internet services, clothing and apparel, precious stones and gems, and defense. He has extensive experience with all issues arising from OFAC licensing, compliance and enforcement matters, as well as the designation and delisting process. Jeremy regularly advises clients on whether certain relationships and/or transactions are prohibited and/or sanctionable under US law.
Prior to joining the firm, Jeremy spent most of his early career as a sanctions investigator and analyst for the Office of Global Targeting within OFAC. During his tenure, Jeremy was the lead investigator responsible for sensitive and complex investigations of Iranian-linked financial institutions and for the first use of the Comprehensive Iranian Sanctions and Divestment Act (CISADA) and first designations of an exchange house and trading company. Additionally, Jeremy headed the investigations and drafted the supporting administrative records for all the designations of Iranian-linked financial institutions during a four-year span.
Jeremy has been cited by the Wall Street Journal, Bloomberg, BBC News, South China Morning Post, Compliance Week and ACAMS MoneyLaundering.com for insights into sanctions and related anti-money laundering developments. A frequent writer, Jeremy is the sole author of many assessments on sanctions law published by Bloomberg and Law360.
Education
- The Pennsylvania State University, Dickinson School of Law, J.D., 2004
- James Madison University, B.S., 2000
Admissions
- District of Columbia, 2016
- Virginia, 2004
- Author, “What New Syria Sanctions Mean For US Companies,” Law360, June 24, 2020.
- Author, “Next US Move Against Iran Could Block Humanitarian Aid,” Law360, August 15, 2019.
- Author, “Compliance Certifications Jack Up Sanctions Violation Costs,” Law360, April 30, 2019.
- Author, “Trump’s Border Emergency Declaration May Undermine Economic Sanctions,” Bloomberg Law, March 6, 2019.
- Presenter, “Doing Business in Cuba,” World Trade Center Denver, July 2017.
- Presenter, “Doing Business in Iran,” The Finance, Credit & International Business Association, April 2017.
- Author, “OFAC Eases Burma Sanctions, But Risks Remain,” Law360, June 6, 2016.
- Presenter, “Opportunities and Legal Risks in the New OFAC Cyber-Related Sanctions Regulations Explored,” The Knowledge Group, April 2016.
- Author, “Lessons From OFAC’s First Public ‘50 Percent Rule’ Penalty,” Law360, February 19, 2016.
- Co-presenter, “Complying with New Russian Sanctions and How the 50 Percent Rule Could Affect Your Existing Business Relationships,” Foreign Corrupt Practices Act Boot Camp, American Conference Institute, January 2015.
- Co-presenter, “Practical Implications to Minimize Facilitation Risks When Dealing with a New or Established Client,” Economic Sanctions Boot Camp, American Conference Institute, December 2015.
- Quoted, “Sanctions Breaches Trigger Mishmash of US Enforcement Actions for Emirati Bank,” ACAMS MoneyLaundering.com, November 10, 2021.
- Quoted, "Fall of Afghanistan Leaves US Officials Scrambling Over Taliban Funding Streams," ACAMS MoneyLaundering.com, August 18, 2021.