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AML Considerations for Investments in Cannabis-Related Businesses


Speaker(s): Darshak S. Dholakia, Robert J.. Rhatigan
Recorded on: Jun. 16, 2020
PLI Program #: 301058

Darshak S. Dholakia primarily advises on compliance with international trade laws, including economic sanctions programs administered by the Office of Foreign Assets Control (OFAC), anti-money laundering (AML) provisions of the USA Patriot Act, the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws, and export controls (Export Administration Regulations (EAR), the International Traffic in Arms Regulations (ITAR), and the Part 110 and 810 nuclear export control regulations). Mr. Dholakia regularly conducts internal investigations, develops compliance programs, oversees risk assessments, conducts due diligence for corporate transactions and interacts with government agencies in relation to compliance and enforcement-related proceedings.

Mr. Dholakia also advises clients in connection with transactions implicating national security reviews conducted by the Committee on Foreign Investment in the United States (CFIUS). He has represented foreign investors and acquirers and domestic sellers and targets in connection with many dozens of investment transactions, and, when necessary and appropriate, he has negotiated national security agreements in order to secure CFIUS approval.

Mr. Dholakia is co-author of the United States chapter of Global Legal Insights - Bribery & Corruption, a book covering bribery and corruption law in 27 jurisdictions that provides an overview of the law and enforcement regime, enforcement activity during recent years, issues relating to investigation and enforcement decisions, corporate liability and proposed reforms in the years ahead. Mr. Dholakia also has authored articles for the Global Trade and Customs Journal and the Anti-Corruption Report and has provided commentary for Bloomberg and Law360. In recognition of his significant work on pro bono matters, Mr. Dholakia has made the Capital Pro Bono Honor Roll numerous times, an initiative sponsored by the District of Columbia Court of Appeals and the Superior Court of the District of Columbia.

Prior to joining Dechert, Mr. Dholakia was an associate in the international trade and investment group of an international law firm. He also previously clerked in the United Nations Office of Legal Affairs.


Robert J. Rhatigan focuses his practice on financial services regulation, including financial institutions and broker-dealer regulation, registered funds and private funds.

Mr. Rhatigan advises registered funds and their boards and investment advisers on a variety of operational, compliance and disclosure matters. He also is actively engaged in the firm’s banking and financial institutions practice before the Federal Reserve Board, FDIC, NCUA, NY Department of Financial Services and the SEC. He works with large non-bank financial holding companies as well as banks, broker-dealers and asset managers on matters arising under the Dodd-Frank and Bank Holding Company Acts. He has significant experience guiding clients through conformance with the Volcker Rule and systemic risk regulation. He also has experience with a variety of transactional, regulatory and enforcement issues related to national and state chartered banks and credit unions, as well as government sponsored entities.

Mr. Rhatigan also advises financial institutions and asset managers on all areas related to compliance with the Bank Secrecy Act and related FinCEN anti-money laundering regulations.