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Carlton Fields Launches Global Anti-Corruption Practice

WASHINGTON, DC – Responding to businesses facing an intensified focus on international transactions, evolving regulations, and enhanced enforcement by government agencies, Carlton Fields has launched a Global Anti-Corruption Practice. The group is led by shareholder Thomas Sjoblom and senior counsel Thomas Morante.

With more than a dozen former federal prosecutors and high-level Department of Justice (DOJ) and Securities and Exchange Commission (SEC) enforcement attorneys, the group represents individuals and companies involved in government investigations concerning anti-corruption laws, foreign payments, accounting and internal controls, foreign agent registration, economic sanctions and export control regulations, anti-money laundering laws, and anti-boycott laws. Additionally, the group counsels and offers comprehensive global guidance to companies and individuals involved in international business transactions.

“After a hiatus in enforcement during the COVID-19 pandemic, the DOJ and SEC have increased their scrutiny of businesses engaged in cross-border and international transactions,” said Sjoblom. “Carlton Fields has represented an international clientele in countries such as Mexico, Brazil, Ecuador, Colombia, and India. The creation of this practice was a natural response to the work we already do every day on their behalf and a natural outgrowth and expansion of our national White Collar practice.”

Key areas of focus for the Global Anti-Corruption Practice include experience with the Foreign Corrupt Practices Act (FCPA), the Department of the Treasury’s Office of Foreign Assets Control (OFAC), DOJ enforcement of the Foreign Agents Registration Act (FARA), and anti-money laundering laws such as the Bank Secrecy Act, the Money Laundering Control Act, and the Patriot Act. The group advises clients in the insurance, banking and finance, transportation, pharmaceutical, telecommunications, information technology, and oil and gas industries.

“Carlton Fields possesses a deep understanding of clients' industries and the cultural nuances to anti-corruption challenges across diverse regions,” added Morante. “Reinforced through our international desks and relationships with foreign law firms around the world, we’re able to represent clients from Latin America, the Caribbean, Asia, and Europe doing business in the United States, as well as U.S. and non-U.S. clients doing business elsewhere around the world.”

Prior to entering private practice, Sjoblom spent nearly 20 years at the SEC, initially as special counsel in the Division of Market Regulation (now Division of Trading and Markets) but most of his SEC career as an assistant chief litigation counsel in the SEC's Division of Enforcement. He has deep international experience appearing on behalf of the U.S. government in court enforcement proceedings in Europe and the Netherlands Antilles. He has also been called upon by several European and Asian governments and securities exchanges to advise on investigating and prosecuting market manipulation and market abuse schemes.

For more than 30 years, Morante has advised clients on U.S. and foreign insurance regulatory, compliance, and transactional matters, as well as cross-border business operations, with a focus on Latin America. Collaborating with international law firms, he also handles regulatory compliance and enforcement matters abroad. Morante also counsels clients on OFAC regulations and related sanctions programs, the Patriot Act and the Anti-Money Laundering Act of 2020, administered by FinCEN, and the recently-adopted Corporate Transparency Act.