Shas counsels clients on compliance and enforcement matters before the SEC, PCAOB, and federal banking regulators.  He also advises clients on anti-money laundering requirements, US economic/trade sanctions, and export control regulations. His clients include large financial institutions, community banks, 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. 

Before joining the firm, Shas served as an Associate Director at the PCAOB, where he 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 Senior Sanctions Advisor, Shas served as the Office of Foreign Asset Control’s 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 violations of sanctions requirements, and presented at more than 40 conferences throughout the US on compliance with US 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 was instrumental in developing 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.

Relevant Experience

• Represented a Texas-based bank in response to an Administrative Subpoena issued by OFAC regarding a funds/wire transfer in connection with the delivery of certain medical-related software for the benefit of an Iranian entity. The matter was favorably resolved for the client as OFAC issued a “no-action” letter upon the completion of its investigation and after reviewing our response;
• Counseled investment firm, specializing in investments in energy-related projects, on the applicability of US sanctions toward Venezuela with respect to a transaction involving payments to a Venezuelan entity (majority-owned by PdVSA) in US dollars for the extraction and sale of Venezuelan natural resources;
• Advised large multi-national beverage company and its subsidiaries regarding the applicability of US sanctions with respect to its proposed business transactions in Venezuela and Cuba, including helping to obtain favorable interpretive guidance;
• Counseled large multi-national payment processor based in Latin America with respect to the application of US sanctions to its global operations;

• Conducted due diligence for community bank as part of capital raising efforts;
• Evaluated proposed joint venture arrangements to assess compliance with US sanctions requirements;
• Conducted AML and sanctions reviews in the context of mergers and acquisition, lending arrangements, and repurchase transations;
• Conducted analysis of client risk due to client activity in sanctioned countries and other high risk countries. Assist in developing a comprehensive cross-business view of AML and sanctions risk;
• Developed AML/sanctions compliance program for a provider of prepaid access utilizing toll road transponder devices, and conducted a risk assessment to create targeted procedures and internal controls;
• Evaluated AML and OFAC obligations of foreign bank client extending margin loans to non-US customers of a US introducing broker;
• Advised on application of BSA/AML/Sanctions requirements to entities in diverse industries including telecommunications, investment companies and hedge funds; residential mortgage loan originators (RMLOs), and public REITS in cross border ventures;
• Advised on US sanctions-related and export control issues involving the sale of goods by a European-based client with US subsidiaries to a Russian buyer;
• Addressed CIP and sanctions related issues raised by cash pooling arrangement for a large multi-national company;
• Prepared legal opinion on foreign based company’s proposed business expansion in sanctioned countries and US regulatory implications;
• Successfully obtained commodity classification determinations from US Department of Commerce on behalf of bio-tech client;
• Advised large financial services company on export control requirements and implications relating to migration to organization-wide office suite/technology with data servers located outside of the US. Raised important “cloud computing” issues;
• Prepared comment letters on behalf of large trade association on various SEC rulemakings;
• Advised on Rule 144A and Regulation S offering;
• Represented PCAOB-registered accounting firm facing disciplinary action involving cross-border access to audit work papers;
• Counseled developer of search engine on AML/OFAC obligations of financial institutions;
• Advised multi-national global industrial firm on compliance with Ukraine/Russian sanctions;
• Assisted multiple clients with obtaining exclusions from the Section 232 tariffs (BIS) imposed on steel/aluminum;
• Advised clients on the application and impact of Section 301 tariffs (USTR);

• Conducted US sanctions and PEP due diligence on behalf of client/buyer of real estate property in New York;

• Obtained favorable determination that cryptocurrency company preparing an ICO did not need to register as an "MSB" under state law;

• Represented medical/research center in response to FINRA request for information relating to possible insider trading violations.

Media Appearances

• C-SPAN, Chinese Investment in the US, Part 3 (Shas featured), January 26, 2017

Bar Admissions

Education
JD, Northeastern University School of Law, 1994BA, History, University of Virginia, 1990