Jeremy Paner is a former Office of Foreign Assets Control (OFAC) official with over a decade of experience handling complex economic and trade sanctions matters. He leverages his sophisticated governmental and private sector experience to deliver legal and risk analysis for strategic business planning, in addition to compliance and enforcement mitigation advice.
Jeremy counsels and represents U.S. and foreign businesses in a wide range of industries on compliance with economic and trade sanctions. 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 U.S. law. He has been cited by the Wall Street Journal, Bloomberg, Compliance Week, and ACAMS MoneyLaundering.com for his insights into sanctions and related anti-money laundering developments.
Jeremy represents clients under investigation by the government and conducts independent internal investigations of potential violations of law and prepares voluntary self-disclosures of apparent violations that minimize potential exposure to civil and criminal penalties.
Jeremy regularly obtains favorable specific licenses and interpretive guidance from OFAC on complex areas of regulatory compliance. These licenses permit transactions that would otherwise be prohibited by law. As part of his practice, Jeremy also drafts sanctions compliance policies and procedures and provides accompanying employee training.
Prior to joining Ferrari & Associates in May 2019, Jeremy was Of Counsel at major national U.S. law firm, where he served as the firm’s sanctions expert. He counseled clients in a wide range of industries on compliance with U.S. sanctions, to include financial, cryptocurrency, asset management, heavy equipment, automotive, mining, media, entertainment, freight forwarding, electronics, food and beverage, communications and internet services, clothing and apparel, and defense. During his tenure at that law firm, Jeremy also assisted in the successful removal of sanctions imposed against over 40 individuals and entities.
Prior to joining his prior law firm in 2014, Jeremy worked for a major international consulting company that served as the New York State Department of Financial Services (NYDFS) appointed independent economic sanctions monitor of a major international financial institution. Jeremy assisted in providing remedial enhancements to the bank’s compliance program throughout its worldwide operations.
During his six years within the Office of Global Targeting within OFAC, Jeremy served as the lead sanctions investigator responsible for imposing targeted sanctions against Iranian-linked financial institutions. Jeremy was responsible for the first uses of secondary sanctions against Iran, as well as the first sanctions designations against an exchange house and a trading company. In his role as a lead sanctions designations targeter, Jeremy provided analytical support directly to the highest-ranking government official responsible for economic and trade sanctions and regularly briefed senior-level Treasury officials on Iran-related terrorism and weapons proliferation finance matters. In addition to investigating and imposing sanctions, Jeremy also adjudicated dozens of petitions from individuals and entities seeking removal from the SDN List.