Overview
白阿里律师专精于代表美国和非美国客户在亚太地区处理与美国经济制裁、出口管制、《美国反海外腐败法》(FCPA)、及反洗钱(AML)法律相关事务。
白律师多次代表客户与美国司法部、美国财政部外国资产控制办公室(OFAC)、及美国商务部工业与安全局(BIS)交涉。白律师在开展跨境调查、提交自愿自我披露、回应传票、取得OFAC许可证、进行风险评估、及寻求将个人和公司从OFAC的特别指定人士名单(SDN名单)和BIS名单中移除方面拥有丰富的经验。
白律师经常为在高风险行业或国家投资的公司针对制裁、反贿赂和腐败、及出口管制相关的收购前尽职调查和收购后合规计划实施提供法律意见。
- Registered Foreign Lawyer, Hong Kong
- District of Columbia
- New York
- J.D., Albany Law School of Union University, 2001
- LL.M. in Banking and Finance Law, Queen Mary University of London, 1998
- B.A., Sewanee: The University of the South, 1994, Economics
Areas of Work
Representative Matters
Investigations & Enforcement
- Representing an Asia-based global oil and gas trading company in relation to a multi-agency sanctions-related investigation by DOJ, Homeland Security Investigations (HSI), and the FBI.
- Successfully represented a Singapore-based commodity trader in front of DOJ and FBI relating to allegations of violations of US sanctions and anti-money laundering laws. As a result of the representation, DOJ issued a declination letter and the client did not have to pay a monetary penalty despite the fact that the initial allegations by DOJ and FBI suggested more than USD 200 million in suspect transactions over a five-year period.
- Successfully represented a South Asian refiner in relation to an inquiry from the State Department relating to a suspected shipment of Iranian crude oil. Following our submissions on behalf of the client, the State Department concluded its inquiry without any further action against our client.
- Represented a major European aircraft manufacturing company in relation to a regulatory investigation arising from alleged violations of US sanctions and export controls.
- Represented a major South American airline in relation to a regulatory investigation by the US Department of Commerce.
- Represented a Chinese telecommunications equipment manufacturing company in relation to alleged violations of US sanctions and export controls.
- Represented major European and Middle Eastern banks in relation to regulatory investigations arising from alleged violations of OFAC sanctions programs.
Compliance & Advisory
- Advised a global mining company on a group-wide risk assessment of its compliance with US, UN, EU and UK sanctions, export controls and AML/CTF requirements.
- Served as US sanctions and export controls counsel to major international banks, logistics companies, commodity trading companies, and oil and gas companies.
- FCPA counsel to a solar power company with investments and projects throughout South Asia and South East Asia.
- Represented private-equity clients in connection with due diligence on highly complex M&A transactions in Asia, the Middle East, and Africa related to sanctions, AML, and anti-bribery and corruption issues.
Speaking Engagements
- "Fighting Digital & Corporate Crime, Investigations & Digital Assets — HK, China & US Focus," Asia Forum: 3rd Annual International Arbitration & Competition Law Summit in Hong Kong, May 18, 2023
- "Sanctions and Arbitrations: Perspective from South-East Asia," L2 i-CON International Webinar, April 13, 2023
- "Sanctions and their impact on the rule of law," GAR Live: Hong Kong, October 27, 2022
- "Navigating the New Economic Sanctions Era: Impact on Global Business/Sanctions Risk Management," IPBA's Anti-Corruption & Rule of Law Committee, June 2, 2022
- "Corruption in the Resources Sector," Energy and Resources Law Asia, November 11, 2021
- "Conducting Effective Internal Investigations for Export Violations", Strafford Publications, October 20, 2021
- "US Tech Export Controls, Sanctions Against Chinese Entities in 2020," China Law & Practice podcast, January 7, 2021
- "Hong Kong and China: What is the Future for Export Controls and Sanctions," Annual Forum on Global Economic Sanctions for Canadian Operations, November 19, 2020
-
"Regulatory Due Diligence of the Target Companies in Merger Transactions," Challenges to Cross-Boundary Deal-Making in the Greater Bay Area, Asian Legal Business webinar, September 23, 2020
News & Publications
Publications
Sanctions and International Arbitration: Impact on Substantive and Procedural Issues
Transnational Dispute Management
April 2024
By: 白阿里
Publications
China Law & Practice
February 29, 2024
International Compliance Blog
February 21, 2024
Press Releases
Chambers Greater China Region 2024 Recognizes Steptoe Practices and Lawyers
January 19, 2024
International Compliance Blog
December 29, 2023
By: 白阿里, 宋慧婷, David M. Stetson, Zoey Hong, Wilson Zhao
Press Releases
The Legal 500 Asia Pacific 2024 Recognizes Steptoe Lawyers and Practice
December 6, 2023
Press Releases
Global Investigations Review Names Steptoe a Top 30 International Investigations Firm
November 21, 2023
Publications
The Guide to Sanctions – Fourth Edition
Global Investigations Review
September 2023
By: Renato Antonini, 白阿里, Eva Monard, Meredith Rathbone, 宋慧婷, Byron Maniatis, Ryan Pereira, Elli Zachari
International Compliance Blog
Commerce, Treasury, and Justice Issue Joint Compliance Note on Voluntary Self-Disclosure
July 31, 2023
By: Wilson Zhao, 宋慧婷, 白阿里, Jack R. Hayes, David M. Stetson, Brian J. Fleming, Edward J. Krauland, 岳 波
Resources
Client Alerts
February 23, 2021
Client Alerts
Singapore Data Protection: Considerations for Data Driven Compliance Activities
February 1, 2021
By: Lucinda A. Low, 宋慧婷, 白阿里
Client Alerts
FCPA/Anti-Corruption Developments: 2020 Year in Review
January 19, 2021
By: Lucinda A. Low, Zoe Osborne, Brigida Benitez, Alexandra Baj, Christopher R. Conte, Alexandra Melia, 白阿里, Fernando Q. Merino, 宋慧婷, Rachel B. Peck, Jefferson Klocke, Veronica Ganzitti, 黄 静 纯, Troy Shephard, 杨 琳, 岳 波, Lucas Caiado (International Regulation & Compliance Intern), Jordan Cannon (Law Clerk), Marcia Pulcherio (International Trainee)
Client Alerts
HKSE Listing Applicants: What You Should Know about Sanctions and Export Controls Due Diligence
October 21, 2020
Client Alerts
White House Memorandum Sets Out Best Practices for Agency Enforcement Actions
October 9, 2020
Client Alerts
US Weighs Further Xinjiang-Related Enforcement, Including Cotton Import Ban
September 9, 2020
By: Meredith Rathbone, Gregory S. McCue, 宋慧婷, 白阿里
Client Alerts
Assessing the Impacts of Executive Order 13936 on Hong Kong's Status, One Month Later
August 25, 2020
By: Alexandra Baj, 白阿里, Eric C. Emerson, Edward J. Krauland, Michelle L. Levin, Patrick F. Linehan, Meredith Rathbone, 宋慧婷, Martin Willner, Jacob Nelson (International Trade Assistant)
Client Alerts
Due Diligence: Top 10 Benefits of Hiring Independent Compliance Counsel
August 4, 2020
By: Lucinda A. Low, 宋慧婷, Meredith Rathbone, 白阿里
Client Alerts
Top Ten Changes to the DOJ/SEC FCPA Resource Guide
July 20, 2020
By: Lucinda A. Low, Christopher R. Conte, Brigida Benitez, 宋慧婷, 白阿里, Jefferson Klocke
Events
Seminars & Events
Global Trade and Enforcement Symposium in Hong Kong
June 1, 2023
Speakers: Renato Antonini, Yongqing Bao, Brigida Benitez, Brian G. Burke, 白阿里, 曹 晖, John Caracappa, Boyd Cloern, Robyn C. Crowther, Brian J. Fleming, Coy Garrison, Stacie R. Hartman, Zoey Hong, Stanley C. Kuo, Amy J. Lentz, Michelle L. Levin, Patrick F. Linehan, Lucinda A. Low, Jamie Lucia, Alexandra Melia, Cáitrín McKiernan, Eva Monard, Darryl Nirenberg, Gwendolyn Prothro Renigar, Angus Rodger, Guy Soussan, David M. Stetson, 王越玥, Philip R. West, Charles Whiddington, 宋慧婷, 杨 琳, 岳 波, Wilson Zhao
Noteworthy
- Chambers Greater China, Corporate Investigations/Anti-Corruption (2023-2024)
- Chambers Asia-Pacific, Corporate Investigations/Anti-Corruption (International Firms), Greater China Region (2022 - 2023)
- Legal 500 Asia Pacific, Regulatory: Anti-Corruption and Compliance, Hong Kong (2022 - 2024)
Previous Employment
-
US Department of Treasury, Office of Foreign Assets Control