Former Senior Government Economic Sanctions Official Joins Gibson Dunn in D.C.

August 4, 2015

Gibson, Dunn & Crutcher LLP is pleased to announce that Adam M. Smith, former Senior Advisor to the Director of the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), has joined the firm’s Washington, D.C. office as of counsel.  At Gibson Dunn, Smith will focus his international trade and investment practice counseling and defending global Fortune 500 corporations, major financial institutions, sovereigns, and international organizations on sanctions, money laundering, international trade, and national security matters.

At OFAC, Smith led efforts to design, explain, and enforce U.S. sanctions, briefed Congressional leaders on sanctions efforts, and led inter-agency delegations to more than 50 countries to engage governments and major private sector actors on sanctions, risk, and compliance.  Of note, Smith played a leading role in implementing the U.S. government’s outreach program to foreign public and private sector partners on Congressionally mandated Iran sanctions and was a primary architect of new Executive Orders, regulations, and policy guidance for both strengthening sanctions (Russia and Syria) and easing measures (Burma and Cuba). 

Earlier in the Administration, Smith served as the Director for Multilateral Affairs at the White House’s National Security Council where he advised the President on the multilateral agenda including with respect to international sanctions, coordinated efforts to relieve U.S. economic restrictions on Burma, and developed strategies to counter corruption and illicit flows and to promote stolen asset recovery.

"Adam is a seasoned international lawyer who has played a major role in almost all significant sanctions actions implemented and enforced by the U.S. government over the past five years, in addition to playing a key part in negotiating parallel measures put into place by allies including the European Union, Canada, Australia, South Korea, and Japan," said Judith A. Lee, Co-Chair of the firm’s International Trade Practice Group.  "There is significant global demand to understand economic sanctions and related matters as they apply in the United States and to U.S. firms, and more broadly.  Adam is well-positioned to help clients navigate the complexities of today’s regulations and to understand and plan for the risks of potential future restrictions."

Smith has significant experience in a wide range of regulations on restrictive measures, including OFAC, Foreign Corruption Practices Act (FCPA), Anti-Money Laundering (AML), and the Committee on Foreign Investment in the United States (CFIUS) regulations.

"Adam’s substantial government experience will complement our white collar and investigatory practice," said F. Joseph Warin, Chair of the Washington, D.C. Litigation Department and Co-Chair of the firm’s White Collar Defense & Investigations Practice Group.  "Between the U.S. government’s intensified enforcement efforts and the international regulations which overlap imperfectly with each other and with those in the U.S. system, our clients will benefit from Adam’s expertise in defending enforcement investigations and in managing the diverse risks and interrelated challenges posed by sanctions, CFIUS, AML, FCPA, and other regulations."

Smith joins more than 50 Gibson Dunn attorneys with governmental enforcement experience.  Before joining the Administration, Smith was an associate with a prominent Washington, D.C. law firm where he advised clients on trade policy, national security, regulatory reform and risk, FCPA, and international investment.  Smith served as a law clerk to Judge James Baker of the U.S. Court of Appeals for the Armed Forces.  He has also held postings with the United Nations in New York, the World Bank / IFC in Washington, DC and abroad, and the OECD in France.  Smith has been a frequent lecturer at universities and think tanks on international economic and national security matters, and is the author of numerous articles and book chapters, and two books, After Genocide – Bringing the Devil to Justice, and International Judicial Institutions – The Architecture of International Justice at Home and Abroad.  He received his law degree magna cum laude from Harvard in 2006 where he was a Chayes Fellow and served as Senior Editor of the Harvard International Law Journal.