Paul Marquardt’s practice focuses on economic sanctions, anti-money laundering, foreign investment review and anticorruption issues.

He regularly advises sophisticated international clients regarding the application of U.S. sanctions and anti-money-laundering laws, as well as export control matters, interacting regularly with OFAC, FinCEN, the Department of State, the Bureau of Industry and Security, and other domestic and international regulators. 

Paul has significant experience in reviews by the Committee on Foreign Investment in the United States (CFIUS), and he has represented clients in a number of high-profile matters. He also has wide-ranging diligence and compliance experience in anticorruption matters under the Foreign Corrupt Practices Act and UK Bribery Act, as well as experience in related complex corporate governance questions and internal investigations.

Paul also advises on a broad range of cross-border transactional matters, particularly in the private equity and financial sectors, including mergers and acquisitions, joint ventures and general corporate transactions. He has substantial public and private international law experience and has represented a number of governments and international organizations.

Paul joined the firm in 1995 and became partner in 2003. From 1998 to 2002, he was resident in the Brussels office. 

Notable Experience

CFIUS Matters

  • American Express in the formation of a global business travel joint venture with an investment group.

  • Brightstar in the acquisition of a 57% interest in Brightstar by SoftBank.

  • GlaxoSmithKline in its acquisition of Novartis’s vaccines and OTC businesses.

  • Google in the sale of Motorola Mobility’s mobile devices business to Lenovo Group.

  • Nortel in the sale of its CDMA/LTE and GSM telecom equipment businesses to Ericsson and other transactions.

  • Parpública in its sale of a stake in Energias de Portugal to China Three Gorges.

  • TPG Capital and PAG Asia Capital in their acquisition of DTZ.

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Enforcement and Sanctions Matters

  • BNP Paribas in its enforcement proceedings involving OFAC, DOJ, NYDFS, Federal Reserve and the Manhattan District Attorney’s Office.

  • Clearstream Banking in its settlement with OFAC involving dealings with the Central Bank of Iran.

  • Leading Russian companies in energy, technology, metals and finance, as well as leading industrial, private equity, and banking firms in connection with Ukraine-related sanctions.

  • American Airlines, a major leisure, travel and entertainment company, and investment funds in connection with Cuba-related sanctions.

  • ArcelorMittal, BNP Paribas, Natixis, PETRONAS, Prudential, SWIFT, TPG, UBAF, Vale and Whirlpool in relation to their sanctions-related compliance policies.

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Selected Activities

  • Vice-Chair of the American Bar Association’s Export Controls and Economic Sanctions Committee.


CFIUS Introduces Pilot Program for Mandatory Declarations of Critical Technology Investments,”Cleary Gottlieb Alert Memo (October 16, 2018)

Congress Passes CFIUS Reform Bill,” Cleary Gottlieb Alert Memo (August 7, 2018) and Wall Street Lawyer (September 2018)


Congress Set to Expand Scrutiny of Foreign Investment in the United States,”Cleary Gottlieb Alert Memo (July 11, 2018)

“United States” chapter, Getting the Deal Through: Foreign Investment Review 2018 (January 2018)

“President Trump Announces Limited Roll-Back of Obama-Era Cuba Sanctions Relief,” Cleary International Trade and Sanctions Watch (Lexblog, June 16, 2017)

“Senate Adopts New Sanctions Targeting Russia and Iran,” Cleary International Trade and Sanctions Watch (Lexblog, June 16, 2017)

“Sovereign Wealth Funds,” (paper presented to the American Bar Association Section of International Law, Sept. 25, 2008)

“Treasury Proposes Changes to the Regulations Governing Exon-Florio ‘National Security’ Reviews of Foreign Investment in the United States,” Mergers & Acquisitions and Corporate Governance (June 2008) 

“The Essential Facilities Doctrine and Intellectual Property Rights: A Response to Pitofsky, Patterson, and Hooks,” 70 Antitrust Law Journal 847 (2003) (with Mark Leddy)

“Law Without Borders: The Constitutionality of an International Criminal Court,” 33 Columbia Journal of Transnational Law 73 (1995)

“Subsidiarity and Sovereignty in the European Union,” 18 Fordham International Law Journal 616 (1994)

“Deficit Reduction: Democracy, Technocracy, and Constitutionalism in the European Union,” 4 Duke Journal Comparative & International Law 265 (1994)