Dr Denis Primakov
Of Counsel, Compliance
Denis advises on sanctions, export controls, anti-corruption and corporate governance — the compliance questions that decide whether a bank keeps an account open and a counterparty signs.
He has practised for more than fifteen years across the United States, European Union, United Kingdom regulatory frameworks, advising multinational corporations, financial institutions, technology companies and international organisations. His work spans the OFAC, EU, UK and UN sanctions regimes, US export controls under the EAR, the Foreign Corrupt Practices Act and the UK Bribery Act, and foreign direct investment and CFIUS screening.
His career includes senior legal and compliance positions in multinationals, financial institutions, international non-governmental organisations and academia. He is the author of three books and numerous publications on sanctions, anti-corruption and regulatory compliance, and a member of the Association of Certified Sanctions Specialists and the Association of Internal Control Practitioners.
Areas of expertise
Select experience
- Advised a UAE-based oil broker on compliance with the G7 and EU oil price cap regime, assessing sanctions requirements and transaction-related compliance risk.
- Led a four-year anti-corruption and compliance programme in Kazakhstan, drafting legislative amendments and evaluating corporate compliance systems under a project supported by the Siemens Integrity Initiative.
- Developed and implemented a comprehensive sanctions compliance programme and internal sanctions policy for a major securities exchange group.
- Led the implementation of a sanctions compliance framework for the local branch of a Japanese bank, including internal controls and sanctions procedures.
- Advised US and European companies over a three-year period on the General Data Protection Regulation, United States privacy regulation, anti-corruption compliance and international sanctions.
- Advised a Serbian oil company on compliance with European Union sanctions regulations and related restrictions.
- Advised an aviation company on European Union sanctions compliance, assessing sanctions risk and operational restrictions.
- Advised on the release of securities and bonds held through Euroclear in accordance with applicable European Union sanctions regulations.
- Provided expert advice on the Swiss and German sanctions regimes and their application to cross-border business.
- Advised international financial institutions on Sharia compliance and related regulatory requirements.
- Prepared OFAC indemnification and sanctions compliance documentation and conducted sanctions impact and risk assessments.
- Advised brokerage firms on sanctions compliance, developing internal screening procedures, controls and policies.
- Developed and implemented anti-corruption compliance programmes, policies and employee training for multiple companies.