Britt Mosman is a partner in and Vice-Chair of the Global Trade & Investment Practice Group in Washington, who advises clients on a wide range of international transactional, compliance, and enforcement issues. Her experience includes advising global financial institutions and leading multinational companies on economic sanctions, Bank Secrecy Act (BSA) / anti-money laundering (AML), and export controls laws, as well as transaction reviews by the Committee on Foreign Investment in the United States (CFIUS) and other national security-related issues. In addition, as part of the Willkie Digital Works team, Britt routinely advises crypto sector participants on how to comply with BSA/AML and economic sanctions requirements.
Britt has deep experience with economic sanctions laws and regulations, having served as an Attorney-Advisor in the Office of the Chief Counsel (Foreign Assets Control) advising the Treasury Department’s Office of Foreign Assets Control (OFAC), prior to joining Willkie. In this capacity, she focused on economic sanctions and national security issues, including as a lead attorney on the Iran, Ukraine/Russia, Cuba, Syria, Election Interference, and Cyber-related sanctions programs.
Her experience includes:
- Guiding major domestic and foreign companies in responding to subpoenas and conducting internal investigations in high-stakes civil and criminal enforcement proceedings by federal and state agencies involving potential violations of sanctions and BSA/AML laws.
- Working with clients in national security reviews at all phases of the transaction life cycle, including conducting CFIUS risk analyses and navigating the CFIUS process through preparation of notices, discussions with CFIUS member agencies, advising on follow-on investigations, and negotiating and implementing mitigation agreements.
- Advising clients on inward and outward foreign investment transactions, particularly transactions that involve the Defense Security and Counterintelligence Agency (DCSA) evaluation of Foreign Ownership, Control or Influence (FOCI), including through Special Security Agreements, Security Control Agreements, Voting Trust Agreements, Proxy Agreements, and Board Resolutions.
- Assisting crypto sector participants in registering as a Money Services Business with the Financial Crimes Enforcement Network (FinCEN), complying with state-level money transmitter laws and other cryptocurrency specific laws (such as the NY Bitlicense), and implementing AML policies and procedures.
- Advising financial institution and crypto sector clients on BSA/AML-related considerations, such as customer identification program / know your customer / customer due diligence requirements and suspicious activity reporting requirements.
- Counseling clients on the full range of sanctions, BSA/AML, and export controls compliance issues.
Britt has deep experience with economic sanctions laws and regulations, having served as an Attorney-Advisor in the Office of the Chief Counsel (Foreign Assets Control) advising the Treasury Department’s Office of Foreign Assets Control (OFAC), prior to joining Willkie. In this capacity, she focused on economic sanctions and national security issues, including as a lead attorney on the Iran, Ukraine/Russia, Cuba, Syria, Election Interference, and Cyber-related sanctions programs. In addition to sanctions, Britt has several years’ experience advising clients on U.S. AML laws and regulations and representing clients navigating the CFIUS process.
Britt is active in the CFIUS Women’s Group and has served as a member of the Awards/Subgrants Team, Young Lawyers Division, American Bar Association (2017-2018).
Britt plays an active role as a thought leader shaping the ongoing policy conversation around international trade and national security issues.
Selected speaking engagements include:
- Speaker, “Insuring Digital Assets and Digitalizing Your Business: New AML & Sanctions Compliance Challenges,” American Conference Institute AML&OFAC for the Insurance Industry Conference (January 2022)
- Speaker, “What’s Putin Planning? Implications for Energy and Order,” Ergo Flashpoints Forum Briefing chaired by former White House National Security Advisor H.R. McMaster, (January 2022)
- Speaker, “Russia Attacks Ukraine,” Ergo Rapid Response Briefing (February 2022)
- Speaker, “Russia-Ukraine Implications – The Next 90 Days,” Ergo Flashpoints Forum Briefing (March 2022)
- Speaker, “Sanctions Against Russia,” Willkie Compliance Concourse Podcast Discussion (March 2022)
- Speaker, “Tensions on the Russia/Ukraine Border – How We Got Here and What’s Next,” Willkie Compliance Concourse Podcast Discussion (January 2022)
- Speaker, “Sanctions and Supply Chain Risks,” Global Investigations Review, Women in Investigations Conference (September 2021)
- Speaker, “New York Department of Financial Services Part 504 Compliance,” Lorman Education Services (April 2018)
Selected publications include:
- “FinCEN Publishes First of Three Proposed Rules on Beneficial Ownership Reporting Requirements,” Investment Lawyer (April 2022)
- “The Practitioner’s Guide to Global Investigations: Sanctions: The US Perspective,” Global Investigations Review (January 2022)
- “The Guide to Sanctions: US Sanctions Enforcement by OFAC and the DOJ,” Global Investigation Review (July 2021)