Davis Polk & Wardwell has added an experienced counsel to its internationally known financial institutions practice.
Charles Steele, who joins Davis Polk as counsel in Washington, was previously a managing director of KPMG’s forensic advisory services practice, where he helped clients grapple with legal issues related to economic sanctions, bribery, money laundering, and fraud. Prior to joining KPMG in 2013, Steele served as associate director of the Office of Foreign Assets Control at the United States Department of the Treasury. In that role, Steele oversaw investigations of and penalty actions against organizations and individuals for violating sanctions. From 2009 to 2011, Steele acted as deputy director of the Treasury Department’s Financial Emergency Crimes Network, which focuses heavily on fighting money laundering. From 2004 to 2006, Steele served as chief of staff to the director of the Federal Bureau of Investigation, and from 1999 to 2003, he held the title of deputy general counsel in the FBI’s Office of the General Counsel.
In his new role, Steele will devote significant time and resources to compliance and enforcement matters and transactions reviews conducted by the Committee on Foreign Investment in the United States (CFIUS).
“I don’t know that the transactions under review have been getting more complex as compared to those in past years, but I do think that there has been a heightened level of scrutiny applied by various CFIUS members, and by the Committee as a whole, to a broad range of transactions in recent years,” Steele told IFLR1000. “For example, the Committee’s annual report to Congress, published last month, indicates a significant increase in the number of notices resulting in investigations in 2013 as compared to the four years before that – 49 % in 2013, up from a yearly average of about 38% for 2009-12.”
Steele attributes the increase, at least in part, to the fact that global events over the past couple of years have raised new, and heightened, national security issues and concerns.
“Just to take one example, the fact that the U.S. and E.U. have imposed sanctions involving Russia can at least potentially contribute to that dynamic. Many of the sanctioned parties in Russia are integrated, their money is integrated, into international markets and economies, in a way that many other sanctions targets are not – for example, parties in North Korea and Cuba. So, a range of transactions involving Russian and Ukrainian parties might now be of more interest to CFIUS than they would have been before the sanctions were imposed,” Steele added.
Steele holds a J.D. from the Georgetown University Law Center.