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Former OFAC Enforcement Officer and Sanctions Compliance Expert Joins Ferrari & Associates

Press Release

WASHINGTON, D.C. (February 1, 2023) – Ferrari & Associates, a leading U.S. sanctions law firm, is excited to announce that Kimberly Brown has joined the firm as Counsel. Ms. Brown has nearly 15 years of experience as a lawyer working in U.S. sanctions, with six years of that experience coming from the time she spent at the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) as a Policy Analyst and Senior Enforcement Officer.

During her time at OFAC, Ms. Brown worked extensively on the Iran sanctions program, including drafting interpretative guidance and the Statement of Licensing Policy on Internet Freedom in Iran, and investigating violations of the Iranian Transactions and Sanctions Regulations (“ITSR”) and other sanctions programs. Further, Ms. Brown drafted and published regulations underlying the Iran sanctions program, including those implementing the provisions of the Comprehensive Iran Sanctions Accountability, and Divestment Act of 2010 (“CISADA”). Ms. Brown also served as the government’s expert witness on sanctions in a criminal prosecution related to the illegal export of telecommunications services to Iran. For that testimony, Ms. Brown received a commendation from the former U.S. Attorney for the District of Maryland.

Prior to her time at OFAC, Ms. Brown spent several years at the Department of Homeland Security (“DHS”), where she served as an Attorney-Advisor in both the Office of Chief Counsel, and the Office of International Trade. During her time at DHS, Ms. Brown advised importers on the proper classification of goods under the U.S. Harmonized Tariff Schedule, and issued administrative decisions in connection with imports or attempted imports in violation of customs and international trade laws.

Since leaving government, Ms. Brown has remained in the sanctions and international trade compliance space working at both IBM, as well as Payward, Inc. (aka “Kraken”), a virtual currency exchange and infrastructure company. At IBM, Ms. Brown served as the OFAC and ITAR Lead, and in that role updated IBM’s compliance manual, conducted export compliance reviews, and reviewed service agreements to ensure compliance with OFAC, ITAR, and EAR regulations. At Kraken, Ms. Brown supervised a team conducting sanctions screening and blockchain transaction monitoring; led investigations of U.S., EU, UK, and UN sanctions issues; drafted and reviewed

sanctions compliance policies and procedures; and conducted risk assessments and implemented controls to remediate compliance gaps.

“I’m very excited to have Kimberly join us,” said Erich Ferrari, Ferrari & Associates’ Founder and Principal. “I remember having cases before OFAC Enforcement when Kimberly was there, and she was always very fair and pleasant to work with. She is widely regarded amongst her peers as being incredibly smart, objective, and professional. We are lucky to have her join our team.”

“I look forward to working with my colleagues to provide exceptional legal and compliance- related services to the firm’s clients.” explained Ms. Brown. “My career in both the public and private sector has given me a more nuanced and unique view of sanctions laws and regulations and their practical implementation.” Ms. Brown will bring her extensive experience in sanctions compliance and investigations, and her deep knowledge of the Iran sanctions program, to strengthen and refine the compliance advice the Firm provides to its clientele. Also, Ms. Brown’s experience in drafting policies and procedures, conducting risk assessments, and remediating compliance gaps for those operating in the virtual currency industry will be a huge value add for the Firm’s growing number of clientele in that industry.

Ms. Brown’s addition continues the tradition of top-level U.S. sanctions experts joining the Firm, with nearly half of Ferrari & Associates’ staff being former governments officials who have worked in the sanctions and anti-money laundering space. The Firm continues to be a leader in the field of U.S. economic sanctions, and Ms. Brown’s addition further cements that position.

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OFAC Compliance
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Significant Cases