Shaswat K. Das 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.
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 a landmark agreement with the Chinese authorities 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.
- J.D., Northeastern University School of Law
- B.A. History, University of Virginia
- District of Columbia
- The Collegiate Schools Alumni Board Member
- UVA Asian and Asian Pacific American Alumni Network (Board member)
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