Adam M. Smith is a partner in the Washington, D.C. office of Gibson, Dunn & Crutcher. He is an experienced international lawyer with a focus on international trade compliance and white collar investigations, including with respect to federal and state economic sanctions enforcement, CFIUS, the Foreign Corrupt Practices Act, embargoes, and export controls. In 2019, Mr. Smith was ranked nationally by Chambers USA as a leading attorney in International Trade: Export Controls & Economic Sanctions. Mr. Smith was also identified by Global Investigations Review as one of the leading sanctions practitioners in Washington, DC.
From 2010-2015 Mr. Smith served in the Obama Administration as the Senior Advisor to the Director of the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and as the Director for Multilateral Affairs on the National Security Council. At OFAC he played a primary role in all aspects of the agency’s work, including briefing Congressional and private sector leadership on sanctions matters, shaping new Executive Orders, regulations, and policy guidance for both strengthening sanctions (Russia and Syria) and easing measures (Burma and Cuba), and advising on enforcement actions following sanctions violations.
Mr. Smith travelled extensively in Europe, the Middle East, Asia, Africa, and the Americas conducting outreach with governments and private sector actors on sanctions, risk, and compliance. This outreach included meetings with senior leadership in several sectors including finance, logistics, insurance and reinsurance, energy, mining, technology, and private equity.
Mr. Smith frequently chaired the Treasury delegation to EU/G7 consultations regarding Russia sanctions and negotiated with EU institutions and member states to implement coordinated measures. Additionally, Mr. Smith managed the development and implementation of the U.S. government’s international outreach program on Congressionally-mandated Iran sanctions and helped develop proposed sanctions relief strategies as a part of the Iranian nuclear negotiations.
During Mr. Smith’s tenure on the White House’s National Security Council he advised the President on his multilateral agenda including with respect to international sanctions, coordinated inter-agency efforts to relieve U.S. economic restrictions on Burma, and developed strategies to counter corruption and illicit flows and to promote stolen asset recovery.
Representative engagements include:
- Successfully represented a regional financial institution before OFAC and other agencies in responding to a subpoena following revelations of potentially sanctionable conduct.
- Assisted U.S. branch of a foreign financial institution in successfully responding to multi-agency regulatory inquiries and examinations.
- Ongoing sanctions representation for major corporation addressing multi-agency civil and criminal enforcement.
- Advised the board of directors of major financial institution in addressing sanctions governance short-falls and assisted the bank in developing robust policies, procedures, and training protocols.
- Providing ongoing sanctions, anti-corruption, and AML compliance advice to major financial institutions, Fortune 500 manufacturers, and insurers.
- Overhauled sanctions compliance oversight and processes at a major e-payments company.
- Retained by a Fortune 100 manufacturer to conduct an internal FCPA investigation and provided sanctions advice in the context of a proposed deal.
- Worked with a major manufacturer to obtain regulatory approvals for sale of products into high-risk jurisdiction and to manage ongoing licensing and compliance issues.
- Advised a multinational food company about the sanctions and corruption risks of proposed ventures, and worked with the firm to limit regulatory risks of resuming long-suspended operations in a challenging foreign jurisdiction.*
Mr. Smith has been a frequent presenter to industry and academic audiences on international economic and national security matters, and is the author of numerous articles, book chapters, and three books.
- U.S., EU, and UN Sanctions: Navigating the Divide for International Business (with Stephanie L. Connor and Richard W. Roeder), (Bloomberg Law, 2019)
- Sanctions Compliance and Opportunity, Singapore Institute of Directors, Directors Bulletin (Q4, 2018)
- International Judicial Institutions – The Architecture of International Justice at Home and Abroad (Routledge, 2015)
- After Genocide – Bringing the Devil to Justice (Prometheus Books, 2009)
Recent speaking engagements include:
- Invited Panelist, “AML/OFAC Enforcement Update,” Bahamas Financial Services Board, Financial Crimes Enforcement, Compliance and Risk Mitigation Workshop, Nassau, The Bahamas (February 19, 2020)
- Invited Keynote Speaker, “The Emergence of Counter Sanctions – The Growing Risk of Inconsistent Compliance Obligations from the U.S., the EU, Russia, China and Beyond,” ACAMS Roundtable, London, UK (February 13, 2020)
- Keynote Speaker, “Sanctions and the Shipping Industry,” UK Defense P&I Club, Athens, Greece; Limassol, Cyprus (December 3-4, 2019)
- Invited Panelist, “Sanctions – The Trump Administration’s International Economic Policy,” Ruger-Levy Workshop, US Naval War College, Newport, RI (November 5-6, 2019)
- Invited Panelist, “The Humanitarian Impact of US Sanctions on Iran,” The Atlantic Council, Washington, DC (October 29, 2019)
- Invited Presenter, “Maritime Sanctions Implementation – U.S. Sanctions on the Shipping Sector,” Panama City, Panama (October 23-24, 2019)
- Invited Lecturer, “U.S. Sanctions – The Basics, C4ADS,” Washington, DC (October 11, 2019)
- Keynote Speaker, “Trading in Uncertain Times, Sanctions and the Shipping Sector,” UK Defense P&I Club, Singapore (September 12, 2019)
- Seminar, “The Trump Administration’s Targeting of Chinese Companies: Export Controls, CFIUS, and Sanctions,” Beijing, China; Hangzhou, China; Hong Kong, SAR; Shenzhen, China (July 2-5, 2019)
- Keynote Speaker, “Managing Sanctions Risk – Best Practices in Light of Recent and Future Developments,” Association of Singapore Banks, Annual Financial Crimes Seminar, Singapore (July 11, 2019)
- Client Seminars, “Navigating Sanctions in the Trump Era,” Kuala Lumpur, Malaysia; Jakarta, Indonesia; Singapore (July 8-12, 2019)
- Lecturer, “Sanctions Diplomacy,” Maxwell School of Citizenship and Public Affairs / CSIS, Executive Master’s in International Relations Degree Program, Washington, DC (May 24, 2019)
- Panelist, Gibson Dunn webcast, “Anti-Money Laundering and Sanctions Enforcement and Compliance in 2019 and Beyond” (May 21, 2019)
- Panelist, “OFAC: Continuous Change, Challenges and Opportunities,” 27th Annual West Coast AML Forum, San Francisco, CA (May 3, 2019)
- Keynote Speaker, “Exiger Annual ECM Underwriters Dinner,” New York, NY (May 1, 2019)
- Speaker, “Surviving and Thriving Amidst Trade Sanctions and Trade Wars,” G100 – Board Excellence, West Palm Beach, FL (February 13, 2019)
- Speaker, “A Conversation on Sanctions & Tariffs: Financial Tools for Future Strategies,” Washington Seminar, Near East South Asia Center for Strategic Studies, National Defense University, Washington, D.C. (February 5, 2019)
- Co-presenter, annual Gibson Dunn webcast, “Challenges in Compliance and Corporate Governance” (2017 – 2019)
- Panelist, Tariffs, “Trade Policy, and International Security – Implications for Aerospace and Defense M&A,” Aviation Week A&D Mergers and Acquisitions Conference, Beverly Hills, CA (November 7, 2018)
- Invited Speaker, Singapore Institute for Directors – “Navigating the Way Ahead for Singapore Institutions in the Trump Era,” Singapore (October 23, 2018)
- Invited Speaker, Association of Singapore Banks – “Economic Sanctions under President Trump,” Singapore (October 22, 2018)
- Speaker, ACAMS Webinars – Sanctions Update – “Keeping Up with Sanctions Changes with Robust Oversight Initiatives” (September 26, 2018)
- Speaker, “A Comprehensive Overview of US Sanctions and Their Extra-Territorial Application at the 4th Forum on Economic Sanctions Compliance & Enforcement, Toronto, Canada (September 24, 2018)
- Invited Keynote, “An Introduction to Sanctions,” U.S. Department of State Foreign Service Institute (July 30, 2018)
- Featured Guest, McCain Institute for International Leadership Podcast: “In the Arena”, speaking about sanctions and human rights (June 15, 2018)
- Invited Address, Navigating U.S. Economic Sanctions in Asia, American Chamber of Commerce – Taiwan, Taipei (May 17, 2018)
- Invited Speaker, The Trump Trade Agenda, Barclays Investment Advisory Client Event, London, UK (May 10, 2018)
- Co-presenter, Gibson Dunn webcast, “Anti-Money Laundering and Sanctions Enforcement and Compliance in 2018 and Beyond” (May 3, 2018)
- Invited Testimony, U.S. Congress’ Commission on Security and Cooperation in Europe (U.S. Helsinki Commission) on the Global Magnitsky Act (March 13, 2018)
- U.S. Sanctions 101 – How OFAC Works, Harvard Law School (Harvard National Security & Law Association), Cambridge, MA (March 6, 2018)
- Theory and Practice in Euro-Atlantic Relations – The Case of Russia Sanctions, Harvard University (Davis Center for Russian and Eurasian Studies), Cambridge, MA (March 6, 2018)
- Annual Lecture to College Park Scholars on War Crimes and International Justice, University of Maryland – College Park (February 27, 2018)
- Panelist, Security in the New Era of Targeted Sanctions, George Mason University / National Security Institute, Arlington, VA (November 13, 2017)
- Invited Address, “Implementing the Iran Deal,” International Institute for Strategic Studies, Seoul, South Korea (October 26, 2017)
- Key Note Address, Association of Banks in Singapore, “Economic Sanctions in the Trump Era,” Singapore (October 23, 2017)
- Key Note Address, ACAMS – Singapore, “Primary and Secondary Sanctions,” Singapore (October 19, 2017)
- Invited Address, “Sanctions and Export Controls under the Trump Administration,” Airbus Export Controls Annual Meeting, Toulouse, France (October 5, 2017)
- Invited Address, “Sanctions 101 in a New Era,” Innospec Annual Legal Meeting, Barcelona, Spain (October 4, 2017)
- Keynote Speaker, ABA Standing Committee on Law and National Security, Sanctions in the Trump Era, Washington, DC (June 6, 2017)
- Invited Speaker, Transatlantic Policy and Sanctions on Russia, Center for a New American Security, Washington, DC (January 30, 2017)
- Co-chairperson of the 7th Annual New York Forum on Economic Sanctions (December 6-7, 2016)
- Iran – Sanctions Relief Status Check, Super Return Conference, Dubai, UAE (October 18, 2016)
- “US Economic Sanctions and Application to Canadian Industry,” 2nd Canadian Forum on Economic Sanctions Compliance and Enforcement,” Toronto, Canada (October 5, 2016)
- Invited Speaker, PE141 – Terrorism Finance and Economic Sanctions, U.S. State Department, Foreign Service Institute, Washington, D.C. (March 14, 2016; July 6, 2016)
- Invited Speaker, Iran Sanctions after the Relief, New Zealand-United States Business Council, Auckland, New Zealand (March 22, 2016)
- Invited Speaker, Iran Sanctions and Australian Business – Opportunities and Risks, U.S.-Australia Chamber of Commerce, Sydney, Australia (March 28, 2016)
- Invited Speaker, OFAC 101 – Workshop, United States Chamber of Commerce, Washington, D.C. (April 11, 2016)
- Invited Speaker, Sanctions: The Past, Present, and Future of Economic Coercion, Working Group on the Future of U.S.-Russian Relations, Moscow Higher School of Economics, Moscow, Russia (May 16, 2016).
- Invited Speaker, Navigating the New World of Sanctions: Private Equity and the Opportunities, Limits, and Risks in Iran, SuperReturn-US, Boston, MA (June 7, 2016)
- Invited Speaker, International Banking and Iran, Association of Banks in Singapore, Financial Crime Seminar, Singapore (July 13-14, 2016).
- Invited Speaker, Global Economic Sanctions – What do Companies In China Need to Know, EU and American Chambers of Commerce, Shanghai, China (July 19-20, 2016)
- Invited Speaker, Myanmar Sanctions – Past, Present and Future, British-Myanmar Chamber of Commerce, Yangon , Myanmar (July 21, 2016)
- Invited Speaker, Young Presidents Organization, Myanmar Sanctions in 2016, Yangon, Myanmar (July 22, 2016)
- Panelist, Implementing the Iran Nuclear Deal: What’s Next? – The United States’ Sanctions Obligations, The Atlantic Council, Washington, DC (Dec 17, 2015)
- Invited Speaker, What the Iran Nuclear Accord Means for Sanctions Today and Tomorrow, International Institute for Strategic Studies, Istanbul, Turkey (Nov 3, 2015)
- Invited Speaker, Private Equity Investment in Iran: Sanctions, Risks, and Opportunities after the Nuclear Deal, Super Return Middle East, Dubai, UAE (Nov 9, 2015)
- Panelist, Sanctions Compliance in a Dynamic Regulatory Environment, ABA/ABA Money Laundering Enforcement Conference, Washington, DC (Nov 16-17, 2015)
- Panelist, “OFAC Cyber Sanctions – A New Weapons Against Cyber Threats, a New Challenge for Financial Institutions,” ACFCS Cyber Financial Crime Summit, National Harbor, MD (Oct 6, 2015)
- Guest lecturer, “The Rise of Smart Sanctions,” The University of Toronto (Oct 5, 2015)
- Moderator, Industry Panel on OFAC Sanctions in Emerging Payment Systems, Washington, DC (September 18, 2015)
- Speaker, “Everything you Ever Wanted to Know about U.S. Sanctions on Russia but were Afraid to Ask,” Georgetown School of Foreign Service, Washington, DC (April 14, 2015)
- Speaker, “U.S. Economic Measures to Combat Russian Aggression in Ukraine,” American Chamber of Commerce in Ukraine, Kiev, Ukraine (March 16, 2015)
- Speaker, “U.S. Economic Pressure on Russia – A New World of Sanctions,” Finnish Exporters Group, Helsinki, Finland (June 2, 2015); Romanian-American Chamber of Commerce, Bucharest, Romania (March 13, 2015); Association of Cyprus Banks, Nicosia, Cyprus (November 12, 2014 ); Association of Serbian Banks, Belgrade, Yugoslavia (November 6, 2014);
- Speaker, “U.S. Sanctions on Iran,” IISS Seminar with Government and Private Sector Leaders, Amman, Jordan (February 11-12, 2015)
- Featured Panelist, “OFAC Compliance: New Sanctions and Corporate Risks,” Lexis-Nexis Webinar (January 22, 2015)
- Panelist, “Ukraine – Russia Sanctions Overview and Projections,” OFAC Industry and Practitioners’ Symposium, Washington, DC (October 7, 2014)
- Speaker, “Presentation on U.S. and EU Sanctions on Russia,” Hong Kong Association of Banks, Hong Kong (September 10, 2014)
- Speaker, “U.S. Sanctions on Russia – Implications for Central Asia,” Association of Bankers of the Republic of Kazakhstan, Almaty, Kazakhstan (September 5, 2014)
- Speaker, “U.S. Sanctions on Russia – Implications and Challenges for the Regulated Community,” British Bankers’ Association, London, UK (September 4, 2014)
- Speaker, “U.S. Sanctions – Basics, Power, and Potential,” Osgood Center for International Studies, Washington, DC (August 14, 2014)
- Panelist, “Iran Sanctions and Nuclear Negotiations – Prospects,” Truman National Security Project Seminar, Washington, DC (July 31, 2014)
- Speaker, “U.S. Sanctions on Russia – The Toolbox,” George Washington University – Seminar for Scholars of Russian Political Economy, Washington, DC (May 30, 2014).
- Featured Speaker, “U.S. Sanctions Policy and Economic Pressure,” Brookings Institution Seminar, Washington, DC (May 1, 2014)
- Speaker, “Making Sanctions Work,” International Institute for Strategic Studies, Dubai, UAE (March 9-10, 2011)
Mr. Smith is a 2006 magna cum laude graduate of Harvard Law School where he was a Chayes Fellow, the recipient of the Laylin Prize for the best work in international law, and the Senior Editor of the Harvard International Law Journal. He graduated magna cum laude from Brown University in 1996 with a Bachelor of Arts degree in Political Science and Economics, and an M.Phil in Politics from Oxford University in 1998 where he was the Seaton Scholar in Politics at St. Hugh’s College. Following law school, Mr. Smith served as a law clerk for the Honorable James Baker on the U.S. Court of Appeals for the Armed Forces. Mr. Smith subsequently practiced for more than three years at a major international law firm in Washington, DC, where he advised clients on trade policy, national security, regulatory reform and risk, FCPA, and international investment. 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.
*Representation occurred prior to Mr. Smith’s association with Gibson Dunn.