Shas advises clients on U.S economic/trade sanctions (OFAC), anti-money laundering requirements, and export control regulations. In addition, Shas has vast expertise, both from his time in government and private practice, advising on a range of regulatory and compliance issues facing banks, hedge funds, investment advisors, mutual funds, and accounting firms. Shas has experience representing clients before OFAC, USTR, Commerce (BIS), SEC, PCAOB, FINRA, and the OCC. His clients include large financial institutions, Fintech companies, and multi-national manufacturers and distributors.[[--readmore--]]

Prior to joining the firm, Shas had a long career in US government and quasi-government agencies where he served in numerous senior level positions, including: Associate Director at the Public Company Accounting Oversight Board (PCAOB), Senior Sanctions Advisor at OFAC, and Senior Counsel at the US Securities & Exchange Commission and Federal Reserve Board. Shas also served as the head of the compliance examinations unit at Legg Mason, a global asset management firm.

As an Associate Director at the PCAOB, Shas negotiated numerous bilateral agreements with foreign regulators providing for cross-border audit oversight and represented the PCAOB in meetings with international audit standard setters. In particular, Shas was instrumental in negotiating an agreement with the Chinese authorities (CSRC and Ministry of Finance) on cross-border enforcement cooperation in 2013. He also participated in a short term secondment at the OECD, where he assisted its Corporate Affairs Division in updating its Principles of Corporate Governance (adopted by the G-20).

In a prior capacity as a Senior Sanctions Advisor, Shas served as the Office of Foreign Asset Control’s primary liaison to the securities industry. While at OFAC, he developed compliance guidance for the securities industry, provided subject-matter expertise on securities- and banking-related matters, prepared recommendations regarding appropriate OFAC responses to potential violations of sanctions requirements by financial institutions, and presented at more than 40 conferences throughout the US on compliance with U.S. economic and trade sanctions. During the height of the financial crisis, while at the US Treasury Department, Shas participated in both the development and implementation of the Dodd-Frank Act. Among other areas, Shas helped develop the US Treasury Department’s determination on whether to exempt foreign exchange swaps and forwards from the Commodity Exchange Act; he also helped develop the criteria for determining the designations of non-bank SIFIs.

Earlier in his career, as counsel in the Banking Supervision and Regulation Division of the Federal Reserve Board, he served as one of the lead lawyers on a seminal enforcement action brought against a global financial institution for violations of OFAC sanctions as well as deficiencies in its anti-money laundering program. This settled action marked the first in a series of actions brought by US regulators and law enforcement agencies against global foreign banking entities for violations of OFAC regulations due to conduct involving the “stripping” of the identities of sanctions targets in the processing of dollar clearing wire transactions.

Events

Speaker, "SEC Virtual Conference 2022: An Accounting & Reporting Update for Public Companies" ("Hot Button Issues for Public Companies"), The Center for Professional Education, Inc., Washington, DC, May 20, 2022"
Speaker, Russian Sanctions - Business & Policy Implications, Electronic Transactions Associations, Washington, DC, March 9, 2022
Speaker, “OFAC Webinar: Back to the Basics for Small to Midsized Banks,” BSA Coalition, Federal Reserve Bank of Richmond, Richmond, VA, April 24, 2018
Speaker, “Conducting KYC of Third Parties - Best Practices for Conducting Due Diligence,” Virginia Bankers Association, Fairfax, VA, April 17, 2018
Panelist, International Sanctions Compliance, Association of Certified Anti-Money Laundering Specialists, New Castle, DE, February 26, 2018
Speaker, “The Challenges of Negotiating an Agreement with the Chinese Regulators on Cross-Border Audit Oversight,” China-US Business Alliance, New York City, January 23, 2018
Speaker, Annual Anti-Money Laundering and Office of Foreign Assets Control Sanctions Year in Review, ACAMS Virginia Chapter Event, December 12, 2017
Speaker, “Strategies for Effective Auditing and Due Diligence of Third Parties in China: Special Focus on Beneficial Ownership,” 8th Global Forum on Anti-Corruption Compliance in High Risk Markets, Washington, DC, July 25-26, 2017
Panelist, “Banking Compliance,” FCPA Roundtable Discussion, US-China Business Council (USCBC), Washington, DC, May 9, 2017
Speaker, “Omnibus Accounts, Trusts and Other Unique Agreements Due Diligence Scenarios: How to Conduct Strong DD to Mitigate Your Risks,” Flagship Conference on Economic Sanctions Enforcement and Compliance, American Conference Institute, Mandarin Oriental Hotel, Washington, DC, April 24-26, 2017
Panelist, 2017 FCPA and Anti-Monopoly Enforcement Trends in China Roundtable Discussion, US-China Business Council (USCBC), Washington, DC, April 5, 2017
Speaker, Keynote Panel: Trump and Banking–Predictions & Promises, 2017 Retail Banking Conference, at the Trump National Doral Miami Hotel in Miami, FL, March 22-24, 2017
Webinar: Changes in Lease Accounting Standards & Impact on Credit Agreements, February 22, 2017
Speaker, “Current Focus of US Regulators—Hot Buttons & Cross Border Issues,” and “PCAOB & Auditing Developments,” SEC Conference 2016: An Accounting & Reporting Update for US Listed Companies, CPE, Beijing, December 12-13, 2016
Panelist, Disclosure of Beneficial Ownership and Control in Asia: corporate practices, Asian Roundtable On Corporate Governance, OECD, October 25, 2016
Speaker, EU Regulatory Equivalency, Cross-Border Inspections of Audit Firms in China, The Evolving Role of the Audit Committee and Other Developments Impacting Global Audit Quality, National Asian Pacific American Bar Association 2016 Southeast Regional Conference, Arlington, VA, September 30, 2016
SEC Conference 2016: An Accounting & Reporting Update for US Listed Companies, Center for Professional Education, June 2016: speaker on three panels: “Recent Auditing Developments,” “Update on SEC Enforcement Initiatives for Asia-Based Companies,” and “Corporate Governance Best Practices & the Role of the Audit Committee” June 16, 2016
ACAMS Richmond Chapter Event: When Goods Go Bad: Trade Based Money Laundering, May 2016
OECD’s Asian Roundtables on Corporate Governance, (co-sponsored with the securities regulators in India and Thailand), 2014 and 2015
Webcast - The PCAOB & China: The Latest Regulatory Developments, 2014
Financial Markets Securities Compliance Seminar, 2009
Anti-Money Laundering III for Financial Institutions, 2008
Futures Industry Association Law and Compliance Workshop, 2008

Publications

Co-author, AML and Sanctions Compliance Issues Facing Cryptocurrency Companies, Crowdfund Insider, June 4, 2018
Co-author, “Recent Developments in the PCAOB’s Standard-Setting and Related Rulemaking Agenda,” Parts 1 and 2, in 38 Sec. & Fed. Corp. L. Rep. No. 11, and 39 Sec. & Fed. Corp. L. Rep. No. 1 (Thomson Reuters), edited by Sam Wolff, February 15, 2017
Contributor, Sarbanes-Oxley Act in Perspective, Thomson Reuters, 2017 edition
Co-author, Trump Administration’s Impact on Financial Regulation and the SEC, Law360, November 23, 2016

Alerts

Trump Administration Issues New Executive Order Against Venezuela to Prevent a “Fire Sale” Liquidation of Venezuela’s Critical Assets, May 23, 2018
Foreign Investment in the US: An Overview of CFIUS, February 15, 2018
Attorney General Jeff Sessions Announces Return to Traditional Guidelines for Prosecuting Marijuana Crimes; Rescinds Cole Memo Referenced in FinCEN Guidance, January 16, 2018
New CFIUS Legislation Proposed in Response to Chinese Investment, November 28, 2017
FinCEN Warns Banks on North Korean Schemes to Evade Sanctions, November 8, 2017
FinCEN Expands Its Geographic Targeting Orders and Issues Related Advisory, August 30, 2017
OFAC Announces $12 Million Settlement to Resolve Enforcement Action Against Non-US Companies Using US Dollars to Do Business With Iran, August 17, 2017
PCAOB Adopts New Audit Reporting Model, July 12, 2017
FinCEN Issues Advisory on SAR Reporting Obligations Involving Cyber Crime, November 7, 2016
FinCEN Expands Customer Due Diligence Requirements, June 22, 2016
PCAOB Reproposes Standards Relating to Auditor’s Reporting Model – Narrows Scope of “Critical Audit Matters” and Drops “Other Information” Requirement, June 8, 2016
PCAOB Adopts New Audit Firm Disclosure Rules, May 17, 2016

Shaswat K. Das