Kevin E. Gaunt

Kevin helps clients with white collar defense, government and internal investigations, regulatory enforcement, and compliance and sanctions issues. His matters frequently involve national security, economic sanctions and Office of Foreign Assets Control (“OFAC”) regulations, export and trade controls such as the Export Administration Regulations (“EAR”) and the International Traffic in Arms Regulations (“ITAR”), and national security issues such as those arising under the Foreign Agents Registration Act (“FARA”).

He also advises clients on other white collar issues relating to financial crime, anti-money laundering (“AML”), anti-bribery / anti-corruption and the Foreign Corrupt Practices Act (“FCPA”), and government contracting fraud.

Kevin regularly provides compliance guidance to financial institutions and other clients related to closely scrutinized sectors such as the oil and gas industry, cannabis / marijuana industry, and fintech providers. He also assists clients with analyzing potential reporting obligations under the Corporate Transparency Act (“CTA”).

• Secured a Cautionary Letter from OFAC relating to a financial institution client’s voluntary disclosure of apparent violations of the Russia/Ukraine sanctions arising from transactions related to blocked Russian banks.
• Conducted internal investigation for global manufacturing company related to potential violations of the Export Administration Regulations (“EAR”) in connection with the Entity List maintained by the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce.
• Advised numerous clients on the impacts of economic sanctions and export controls imposed on Russia following its invasion of Ukraine.
• Represented military housing provider in civil and criminal False Claims Act (“FCA”) investigation involving allegations of fraud related to requests for incentive fee payments tied to military base housing contracts with the government.
• Coordinated internal investigation and subpoena response for international consulting firm responding to multi-prong government investigation into Russian interference in 2016 elections and related Foreign Agents Registration Act (“FARA”) registration issues.
• Represented specialty vehicle manufacturer in DOJ investigation into potential FCPA violations arising from international sales contracts with a foreign government’s Ministry of Defense.
• Conducted internal investigation for county school board to facilitate board’s response to government investigation into qui tam relator’s allegations of bid-rigging and kickbacks relating to school contractors.
• Counseled South African mining company on OFAC sanctions and risk exposure.

• Recipient of Lawyers Serving Warriors^® Excellence Award, National Veterans Legal Services Program, 2019

• Member, American Bar Association, Criminal Justice Section