Patrick Rowan

Pat’s practice focuses on criminal and civil enforcement proceedings and internal investigations. He has substantial experience in federal law enforcement, as well as international and national security matters. He also advises corporate clients on compliance with the Foreign Corrupt Practices Act, the ITAR, the EAR and OFAC regulations.

Firm/Organization: McGuireWoods LLP

Blogs: Subject to Inquiry

Latest Articles

Subject to Inquiry

What the Venezuela Sanctions May Mean for Future Sanctions Programs

By Alex J. Brackett, Emily P. Gordy, Jeffrey M. Hanna & Patrick Rowan on March 11, 2019

When the Trump Administration designated Venezuelan state-owned oil producer Petreoleos de Venezuela (“PdVSA”) on January 28, 2019, pursuant to preexisting sanctions relating to the political situation created by the Maduro regime, it sent a significant but not unanticipated ripple through the global petroleum markets. The impact of the sanctions for commodities traders and petroleum refiners—particularly in the U.S. Gulf Coast, where PdVSA’s steady supply of heavy crude has long been a sizable staple feedstock—was fairly…

Subject to Inquiry

Congressional Investigations: Beyond Sensational Headlines — Incoming House Leaders Announce Broad Investigative Priorities Targeting Business Community

By John Adams, Ryan Bernstein, Robert J. Bittman, Richard Cullen, Frank J. Donatelli, Louis D. Greenstein, Charles McIntyre, Mona G. Mohib, Susan Rodriguez, L. F. Payne, Jr., Patrick Rowan, Todd R. Steggerda, Brian C. Wanglin & Robert K. Wasinger on December 19, 2018

In the politically explosive atmosphere of Washington, the talk of the town is focused on congressional investigations: who will be called before Congress, and when. Newspaper headlines blare the latest controversy — from use of personal emails for government business, to numerous investigations alleging corruption of current and former government employees, including several cabinet secretaries, and the continuing developments from Special Counsel Robert Mueller’s Russia investigation. But as the nation prepares for power in the…

Subject to Inquiry

Second Circuit Clarifies Limits of FCPA’s Extraterritorial Reach

By Patrick Rowan, Alex J. Brackett & Government Investigations Group on September 7, 2018

The U.S. Court of Appeals for the Second Circuit narrowed the reach of the Foreign Corrupt Practices Act (“FCPA” or “the Act”) in ruling that the government cannot use aiding and abetting or conspiracy statutes to charge a defendant with violating the FCPA if the defendant is not in the category of persons directly covered by the Act. Defendant Lawrence Hoskins, a UK citizen, worked for a UK subsidiary of Alstom S.A. The government alleged…

Subject to Inquiry

FinCEN Opens 2017 with SAR Sharing Guidance for Casinos

By Jeffrey M. Hanna, Matthew Orso & Patrick Rowan on January 9, 2017

Financial institutions’ ability to share suspicious activity reports (“SARs”) within the corporate organizational structure serves as an important tool for Bank Secrecy Act compliance and risk avoidance. FinCEN began 2017 by reminding casinos of their ability to share information under this rule. Subject to certain limitations, casinos may share with domestic parents and affiliates suspicious activity reports and related information under the Bank Secrecy Act (“BSA”). FIN-2017-G001 (January 4, 2017). Under this guidance, such sharing…

Subject to Inquiry

FinCEN Associate Director for Enforcement Delivers Remarks at Title 31 Conference, Stresses Importance of Culture of Compliance

By Jeffrey M. Hanna & Patrick Rowan on September 21, 2016

On the day after his appointment in August 2016, the Associate Director for Enforcement for the Financial Crimes Enforcement Network (FinCEN), Thomas Ott, addressed the National Title 31 Suspicious Activity & Risk Assessment Conference in Las Vegas, Nevada. In his remarks, he (1) covered recent enforcement actions, (2) sought to dispel myths or misconceptions about suspicious activity reports (SARs), (3) provided context for the value to law enforcement of the Title 31 reporting information,…

Subject to Inquiry

The Export/Immigration Dilemma: Don’t Let OSC Catch Your HR Department Unawares

By Alex J. Brackett, David Izakowitz, Patrick Rowan, Christopher M. Michalik, Matthew Orso & Susan Rodriguez on May 5, 2016

On March 31, 2016, the U.S. Department of Justice’s Office of Special Counsel for Immigration-Related Unfair Employment Practices (OSC) issued a carefully worded technical assistance letter addressing the complex interplay between U.S. immigration and export control laws in the context of hiring and applicant screening. Although it provides limited new guidance, OSC’s letter is a reminder of the pitfalls companies of all sizes face in trying to navigate the overlapping requirements of these laws. The…

Subject to Inquiry

Casino AML: FinCEN Fines Former Sparks Nugget Management $1 Million

By Patrick Rowan & Jeffrey M. Hanna on April 7, 2016

Attributing observed deficiencies to a lack of a culture of compliance, FinCEN has again targeted a casino for willful violations of the anti-money laundering (“AML”) provisions of the Bank Secrecy Act (“BSA”). This time the casino in FinCEN’s sights is the Sparks Nugget, Inc. d/b/a John Ascuaga’s Nugget (“Sparks Nugget”), located in Sparks, Nevada. In resolving this matter with FinCEN, Sparks Nugget entered into a consent agreement that, among other things, provided for a…

Subject to Inquiry

Iran Sanctions and the Implementation of the JCPOA: Lots of Changes, but Little Impact on U.S. Businesses?

By Patrick Rowan, Alex J. Brackett & Edwin O. Childs on January 21, 2016

In recent days, the news has been full of stories referring to the “end” or “lifting” of U.S. sanctions against Iran, actions that were taken after the International Atomic Energy Agency confirmed on January 16, 2016, that Iran has met its obligations under the July 14, 2015, Joint Comprehensive Plan of Action (JCPOA) in connection with Iran’s nuclear program. The United States and Iran agreed to a prisoner exchange on the same day, and…

Subject to Inquiry

FinCEN Announces First Card Club AML Enforcement Action

By Jeffrey M. Hanna & Patrick Rowan on January 11, 2016

Just in time for Christmas, the Financial Crimes Enforcement Network (FinCEN), the financial industry (including casinos and card clubs) regulator, announced its first-ever enforcement action against a card club, California’s Oaks Card Club (Oaks). The enforcement action, which carried a penalty of $650,000, is the latest in a string of actions against gaming enterprises and is yet another reminder of the importance of implementing and maintaining an effective anti-money laundering (AML) compliance program. As FinCEN…

Subject to Inquiry

FinCEN Announces Caesars Penalty After Multiyear Investigation

By Jeffrey M. Hanna & Patrick Rowan on September 11, 2015

This week the Financial Crimes Enforcement Network (FinCEN) announced a Consent Agreement that imposed an $8 million civil penalty against Desert Palace, Inc. d/b/a Caesars Palace. Caesars first disclosed the investigation in SEC filings in late 2013. The investigation grew out of a 2012 audit performed by FinCEN’s examiner, the Internal Revenue Service Small Business/Self-Employed Division (IRS SB/SE). In addition to the penalty, the Agreement made factual determinations and imposed “undertakings” – remedial measures –…

Patrick Rowan

What the Venezuela Sanctions May Mean for Future Sanctions Programs

Congressional Investigations: Beyond Sensational Headlines — Incoming House Leaders Announce Broad Investigative Priorities Targeting Business Community

Second Circuit Clarifies Limits of FCPA’s Extraterritorial Reach

FinCEN Opens 2017 with SAR Sharing Guidance for Casinos

FinCEN Associate Director for Enforcement Delivers Remarks at Title 31 Conference, Stresses Importance of Culture of Compliance

The Export/Immigration Dilemma: Don’t Let OSC Catch Your HR Department Unawares

Casino AML: FinCEN Fines Former Sparks Nugget Management $1 Million

Iran Sanctions and the Implementation of the JCPOA: Lots of Changes, but Little Impact on U.S. Businesses?

FinCEN Announces First Card Club AML Enforcement Action

FinCEN Announces Caesars Penalty After Multiyear Investigation

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