Overview

Mike’s practice focuses on representing clients in investigations, transactions, and regulatory matters related to economic sanctions, money laundering, international corruption, fraud, export controls, customs, and national security reviews.

Mike has represented companies in investigations initiated by the Department of Justice, the Securities and Exchange Commission, the Office of Foreign Assets Control, the Bureau of Industry and Security, the Directorate of Defense Trade Control, U.S. Customs and Border Protection, and the Census Bureau. He has conducted numerous internal investigations involving potential violations of economic sanctions, anti-money laundering laws, anti-bribery laws, and export controls in the United States, Europe, Asia, and Central and South America. He has also represented individuals in pending and threatened litigation related to potential violations of the International Emergency Economic Powers Act and the Foreign Corrupt Practices Act. 

Mike regularly advises private equity sponsors and their portfolio companies, financial institutions, hedge funds, pharmaceutical companies, medical device manufacturers, oil and gas companies, and international logistics providers on a wide range of compliance issues. He has drafted policies and procedures for numerous U.S. and foreign companies in a variety of industrial sectors. He regularly works with companies in developing and implementing state-of-the-art compliance programs.

Mike assists clients with carrying out due diligence and making regulatory filings for many types of corporate transactions. He has successfully guided foreign companies through the CFIUS review process in connection with their acquisitions of U.S. companies.

He is the lead author of Sanctions Enforcement and Compliance: A Practitioner’s Guide to OFAC, a book published by Bloomberg BNA. In addition, national journals have published more than 30 of his articles related to sanctions, anti-money laundering, and export controls. Mike has also been quoted by the Wall Street Journal, the New York Times, and Law360.  

Mike maintains an active pro bono practice. He has worked closely with an international NGO in investigating and documenting human rights abuses in Afghanistan, Syria, and Pakistan.

More

Thought Leadership

Books

  • Michael Casey and Zachary Brez, Sanctions Enforcement and Compliance: A Practitioner’s Guide to OFAC, 411 Banking Practice Series Bloomberg BNA (November 2, 2016) 

Selected News

  • Quoted, “Juniper Networks Resolves SEC Charges for $11.7M After Allowing Subsidiary Misconduct to Continue for Years,” The Anti-Corruption Report (October 2, 2019)

  • Quoted, “U.S. Sanctions Enforcers Extend Reach Further Than Ever as UK Bank Fined,” Payments Compliance (September 24, 2019)

  • Quoted, “Iran Tanker Funds Would Have Defeated Many, If Not Most, U.S. Sanctions Filters,” ACAMS MoneyLaundering.com (August 2019)

  • Quoted, “The Perils of Self-Reporting,” Financier Worldwide (August 2019)

  • Quoted, “OFAC Combing Attempts to Skirt Sanctions with Cryptocurrency,” Payments Compliance (July 17, 2019)

  • Quoted, “OFAC Penalty Highlights Risks of Directing Overseas Subsidiaries,” ACAMS MoneyLaundering.com (February 5, 2019)

  • Quoted, “Europe to Tackle Iran Sanctions Crisis with New Payment Measures,” Payments Compliance (November 22, 2018)

  • Quoted, “Trump Ushers in New Sanctions Era with Iran Clampdown,” Law360 (November 5, 2018)

  • Quoted, “Selected Defence—Egypt,” Money Laundering Bulletin (October 22, 2018)

  • Quoted, “OFAC Blacklists Bank Mellat, Eight Other Iranian Financial Institutions,” ACAMS MoneyLaundering.com (October 16, 2018)

  • Quoted, “U.S. Officials Blacklist Russian Bank, North Korean Bank and Front Companies,” ACAMS MoneyLaundering.com (August 3, 2018)

  • Quoted, “Conflicting Messages—Pakistan,” Money Laundering Bulletin (July 9, 2018)

  • Quoted, “Treasury Dept. Hits Russia With New Sanctions,” The New York Times (June 11, 2018)

  • Quoted, “One More Arrow in the Government’s Anti-Corruption Quiver: The Global Magnitsky Act,” The Anti-Corruption Report (May 31, 2018)

  • Quoted, “Russian Aluminum Giant’s U.S. Bondholders Trapped by Sanctions,” Bloomberg (April 13, 2018)

  • Quoted, “Cryptocurrency and Sanctions Risk,” Commercial Disputes Resolution (March 2, 2018)

  • Quoted, “With U.S. Push, Pakistan Placed on Terror Finance List,” The Wall Street Journal (February 23, 2018)

  • Quoted, “Pakistan Could Face Economic Pain from Return to Terrorist Financing ‘Gray List,’” Reuters (February 16, 2018)

  • Quoted, “Trump Administration Slaps New Sanctions on North Korea,” The New York Times (January 24, 2018)

  • Quoted, “Extraterritorial Enforcement Resumes with OFAC Penalty Against African Lender,” ACAMS MoneyLaundering.com (January 18, 2018)

  • Quoted, “Fraudulent Payment Messages Still Plague U.S. Correspondent Banks,” ACAMS MoneyLaundering.com (January 9, 2018)

  • Quoted, “UK Sanctions Enforcer Probing 60 Suspected Cases,” Law360 (October 16, 2017)

  • Quoted, “UK Banks on Alert As New Sanctions Watchdog Sets Sights,” Law360 (October 16, 2017)

  • Quoted, “Sudan Compliance Remains Complicated,” The Wall Street Journal (October 9, 2017)

  • Quoted, “Trump Administration Will Lift Sanctions on Sudan,” Newsmax.com (October 9, 2017)

  • Quoted, “Trump Moves to Ease Sanctions on Sudan,” The Hill (October 9, 2017)

  • Quoted, “U.S. Foreign Ownership Monitor Creates a Minefield For PE,” Private Equity News (August 18, 2017)

  • Quoted, “ExxonMobil Fights Russian Sanctions Fine,” Commercial Disputes Resolution (July 28, 2017)

  • Quoted, “U.S. Imposes New Sanctions Over North Korea Ties,” The New York Times (June 29, 2017)

  • Quoted, “In Unprecedented Move, FinCEN Blacklists Chinese Bank Tied to North Korea,” ACAMS MoneyLaundering.com (June 29, 2017)

  • Quoted, “Cuba Rollback Months Away, Presents Potential Challenges,” The Wall Street Journal (June 19, 2017)

  • Quoted, “Doing Business In Cuba Is About To Get A Whole Lot Tougher,” Law360 (June 16, 2017)

  • Quoted, “Ant Financial/MoneyGram: Buyer’s Chinese Government Ties, Money Transfer Issues Raise Potential CFIUS Concerns,” The Capitol Forum (March 21, 2017)

  • Quoted, “Europe Poised For Flood Of Iran Deals As US Can Only Watch,” Law360 (February 5, 2016)

Articles

  • Michael Casey and Cori Lable, “The U.S. Probe of Chinese Banks—What Counterparties Need to Know,” Bloomberg Law (September 6, 2019)

  • Michael Casey, Cori Lable, Tiana Zhang, and Jodi Wu, "Shifting U.S. Enforcement Priorities—Should Chinese Companies be Worried?" Bloomberg Law (June 17, 2019)

  • Michael Casey, Zach Brez, and Marcus Thompson, “INSIGHT: A Review of U.S. Economic Sanctions in 2018,” Bloomberg Law: White Collar & Criminal Law (January 11, 2019)

  • Michael Casey, Zach Brez, and Nathalie Petritis, “What Société Générale Tells Financial Institutions About the Future of Enforcement,” Bloomberg Law (November 30, 2018)

  • Michael Casey, Marcus Thompson, and Zach Brez, “The Challenge Iran Sanctions Pose for EU Operators,” Law360 (November 2, 2018)

  • Marcus Thompson, Michael Casey, Mark Gardner, and Kartikey Mahajan, “Reform on the Horizon for the United Kingdom’s National Security Regime,” Antitrust on Bloomberg Law (August 21, 2018)

  • Sarah Klein, Michael Casey, and Gavin Costello, “Extraterritorial Sanctions—Going Back to the Future?” Corporate Disputes Magazine (July 2018) 

  • Michael Casey and Zachary Brez, “U.S. Economic Sanctions: Mid-Year Review,” Corporate on Bloomberg Law (July 13, 2018)

  • Michael Casey, Marcus Thompson, and Kartikey Mahajan, “Adding Pakistan to ‘Gray List’ Has Important Consequences,” Law360 (May 23, 2018)

  • Mario Mancuso, Zachary Brez, Sanjay Mullick, and Michael Casey, “Interpreting Treasury’s Report on Russian Oligarchs,” Law360 (February 5, 2018)

  • Michael Casey, Cori Lable, Tiana Zhang, and Ning Ning, “How Should Chinese Companies Face Increased U.S. Enforcement Risk From Their Global Business Operations?” China Business Law Journal (January 31, 2018)

  • Matthew Bell and Michael Casey, “Voluntary Self-Disclosure of Sanctions Violations: Frameworks and Considerations in the US, UK (Part II),” Corporate Counsel (January 22, 2018)

  • Matthew Bell and Michael Casey, “Voluntary Self-Disclosure of Sanctions Violations: Frameworks and Considerations in the US, UK (Part I),” Corporate Counsel (January 19, 2018)

  • Michael Casey, Zach Brez, and Kim Nemirow, “Sanctions Year in Review,” Bloomberg Law Corporate Law & Accountability Report (December 12, 2017)

  • Michael Casey, Marcus Thompson, and Douglas Badder, “How Will Brexit Affect the UK Sanctions Regime?” Financier Worldwide (November 2017)

  • Michael Casey, Asheesh Goel, Taryn Lewis, “Damming Warrants:  The United States’ Latest Foreign Policy Tool?” Bloomberg Law White Collar Crime Report (October 27, 2017)

  • Michael Casey, Zachary Brez, and Mario Mancuso, “Sanctions Compliance Lessons from Recent OFAC Actions,” Law360 (September 13, 2017)

  • Michael Casey, Cori Lable, and Martin De Luca, “U.S. Expands Efforts to Target Corrupt Foreign Officials,” Westlaw Journal White-Collar Crime (August 2017)

  • Michael Casey, Brendan Hanifin, and Emerson Siegle, “OFAC’s Streak Continues: Takeaways from the TransTel Sanctions Settlement,” Bloomberg BNA’s Corporate Law & Accountability Report (August 4, 2017)

  • Michael Casey and Sarah Clinton, “New FinCEN AML and Customer Due Diligence Regulations Await Mutual Funds,” The Investment Lawyer (August 2017) 

  • Michael Casey, Brendan Hanifin, and Emerson Siegle, “OFAC Continues To Pursue Oil And Gas Companies,” Law360 (July 21, 2017)

  • Michael Casey and Brendan Hanifin, “A Midyear Review Of US Economic Sanctions Efforts,” Law360 (June 29, 2017)

  • Zachary Brez, Michael Casey, and Brendan Hanifin, “Sanctions And Export Control Risks For Health Care Companies,” Law360 (May 19, 2017)

  • Michael Casey, Brendan Hanifin, and Emerson Siegle, “Export Control Enforcement In The Wake Of The ZTE Resolution” Law360 (March 10, 2017)

  • Michael Casey and Brendan Hanifin, “Developments in US economic sanctions: 2016 in review,” Global Investigations Review (January 19, 2017)

  • Michael Casey and Brendan Hanifin, “Important Takeaways From the National Oilwell Varco Inc. Settlement,” Bloomberg BNA Corporate Law & Accountability Report (January 2017)

  • Michael Casey, Zachary Brez, and Brendan Hanifin, “Forecasting International Risk Climate Under President Trump,” Law360 (November 13, 2016)

  • Michael Casey, “Recent Trends in Sanctions and AML Regulation and Enforcement,” Bloomberg Law: Banking (October 24, 2016)

  • Michael Casey and Zachary Brez, “Six Months Since Iran Sanctions Relief: Lessons And Forecast,” Law360 (July 28, 2016)

  • Zachary Brez, Michael Casey, and Sean Seelinger, “Potential Traps When Doing Business in Iran,” New York Law Journal (February 10, 2016)

  • Zachary Brez, Marcus Thompson, Michael Casey, and Sean Seelinger, “FinCEN’s Proposed AML Program & Reporting Requirement Rules,” Bloomberg BNA “Securities Regulation & Law Report” (December 2015)

  • Zachary Brez and Michael Casey, “Lessons Learned From the Schlumberger Sanctions Settlement,” Bloomberg BNA “Corporate Law & Accountability Report” (April 3, 2015)

  • Zachary Brez, R. Daniel O’Connor, and Michael Casey, “Takeaways From Weatherford Corruption Settlements,” Law360 (December 5, 2013)

  • Zachary Brez and Michael Casey, “OFAC Sanctions and Successor Liability,” Law360 (November 6, 2013)

  • Zachary Brez and Michael Casey, “The Perilous Sanctions Regime: Understanding ING Bank’s $619M Settlement With OFAC,” Bloomberg BNA's Banking Report (October 30, 2012)

  • Zachary Brez and Michael Casey, “Al Haramain: Analyzing the Impact of the Ninth Circuit’s Recent Decision on OFAC’s Jurisdiction,” Bloomberg Law Reports Corporate Counsel (January 2012)

  • Zachary Brez and Michael Casey, “4 Steps Toward OFAC Sanctions Compliance,” Law360 (August 2011)

Speaking Engagements

  • Speaker, “The Risks Venezuelan Sanctions Present for EU Operators,” Global Sanctions Forum, London (September 24, 2019)

  • Speaker, “Dealing with Russia - Current Sanctions Considerations,” Global Sanctions Forum, London (September 24, 2019)

  • Speaker, “Sanctions Seminar,” The Law Society, London (June 19, 2019)

  • Speaker, “Current Priorities and Compliance Expectations for 2019 and Beyond,” Global Economic Sanctions Forum, Berlin (May 22, 2019)

  • Speaker, “Fundamentals on Russia Sanctions: EU and U.S. Rules on Primary, Secondary and Sectoral Sanctions,” Global Economic Sanctions Forum, Berlin (May 21, 2019)

  • Speaker, “Lessons Learned from Recent AML Enforcement Actions,” 15th Annual AML & Financial Crime Seminar, London (March 25, 2019)

  • Speaker, “Dealing with Iran: U.S. Primary Sanctions, Secondary Sanctions, and the EU Blocking Statute,” AML, Financial Crime, and Sanctions Forum, London (January 31, 2019)

  • Speaker, “The EU Blocking Statute, U.S. Sanctions, and Iran: Compliance Questions and Challenges,” Global Sanctions Forum, London (October 31, 2018)

  • Speaker, “How to Scope, Execute, and Resolve Multi-Jurisdictional Investigations,” 12th Annual International Conference on Anti-Corruption, London (June 28, 2018)

  • Speaker, “Reinstating Sanctions and Strengthening Enforcement on Iran: What’s in Store for European Multinationals,” 12th Annual Exporters’ Forum on Global Economic Sanctions, Berlin (May 24, 2018)

  • Speaker, “Russia Sanctions: Understand Your Exposure and Mitigate Risks,” 12th Annual Exporters’ Forum on Global Economic Sanctions, Berlin (May 22, 2018)

  • Speaker, “Dealing with Iran,” AML, Financial Crime, and Sanctions Forum, London (January 31, 2018)

  • Speaker, “Preparing and Addressing a Voluntary Self-Disclosure,” C5 Economic Sanctions & Financial Crime Conference, London (November 16, 2017)

  • Speaker, “Russia Sanctions from the Oil and Gas Perspective: New Risk and Compliance Expectations,” C5 Global Economic Sanctions Conference, Amsterdam (May 17, 2017)

  • Speaker, “International Risk Developments for Oil & Gas Companies,” Bloomberg BNA Webinar (February 15, 2017)

  • Speaker, “Practical Steps to Implementing FinCEN’s Proposed AML Rule for Registered Investment Advisers,” HFM Breakfast Briefing, New York (February 9, 2017)

  • Speaker, “Emerging Anti-Corruption Trends in Latin America,” Seventeenth Annual Pharmaceutical and Medical Device Compliance Congress, Washington, D.C., (October 19, 2016)

  • Speaker, “Recent Trends in Sanctions and Money Laundering Enforcement,” Chambers Seminar, New York (September 13, 2016)

  • Speaker, “Lessons Learned from the Schlumberger Sanctions Settlement,” Bloomberg BNA Webinar (July 20, 2015)

  • Speaker, “An Introduction to U.S. Economic Sanctions and Export Control Laws,” Pfizer PLACE Session, New York (November 18, 2014)

  • Speaker, “Sanctions and Export Control Issues for International NGOs,” Physicians for Human Rights Seminar, New York (October 2, 2014)

  • Speaker, “Russia/Ukraine Sanctions Update,” Webinar (August 20, 2014)

Recognition

Named a “Rising Star” by Super Lawyers (2014–2017)

Selected to serve on Pfizer’s Associate Roundtable Committee (2013–2015)

Steering Committee Member, American Lawyers in London

Credentials

Admissions & Qualifications

  • 2008New York
  • 2009District of Columbia

Courts

  • United States District Court for the District of Columbia

Education

  • University of California, Los Angeles, School of LawJ.D.2007

    Order of the Coif

    Articles Editor, Journal of International Law and Foreign Affairs

  • London School of Economics and Political ScienceM.Sc., International Relations2004
  • Dartmouth CollegeA.B., International Politics

    with High Honors

    2003