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Britt Mosman

Britt Mosman

Partner, Global Trade & Investment
Washington Washington bmosman@willkie.com bmosman@willkie.com +1 202 303 1057 +1 202 303 1057
Willkie Digital Works Corporate Governance

Britt Mosman is a partner in and Co-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 preparing voluntary self-disclosures, 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.
  • Counseling clients on the full range of sanctions, BSA/AML, and export controls policy and compliance issues.
  • Assisting clients in developing and maintaining sanctions, anti-money laundering, and export controls compliance policies and procedures.
  • Representing lenders, underwriters, borrowers, issuers, and companies in international lending, capital markets, and M&A transactions regarding sanctions and anti-money laundering issues.
  • 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.