Ivan Komaritsky
Counsel
Ivan Komaritsky is a regulatory compliance, corporate crime and litigation attorney advising on FCPA compliance, CFIUS regulations, U.S. economic sanctions. Ivan also represents clients in white collar crime investigations and commercial litigation matters.
Prior to joining Rimon PC, Mr. Komaritsky worked for 12 years at DLA Piper in New York. He advises clients with respect to the Foreign Corrupt Practices Act (FCPA), the Committee on Foreign Investment in the United States (CFIUS), and US economic sanctions and embargoes (OFAC regulations).
Mr. Komaritsky guides clients on developing and implementing multinational compliance programs and policies to address risks of corruption, fraud, embezzlement, and violation of OFAC/sanctions legislation. He has conducted numerous internal investigations and FCPA corporate audits in Russia, Eastern Europe (Romania, Czech Republic, Georgia, Azerbaijan), Middle East (Turkey, UAE, Iraq), Central Asia (Kazakhstan, Mongolia) and South-East Asia (Philippines, Indonesia). Additionally, Mr. Komaritsky carries out third party due diligence in cross-border and M&A transactions minimizing FCPA risks and ensuring appropriate controls are established and executed by clients.
Mr. Komaritsky performs the full cycle of investigation and litigation activities including developing work plans, document reviews, drafting outlines, conducting interviews and depositions, managing discovery requests, and presenting remediation strategies to business leadership teams. He manages document review projects including liaising with vendors, training review teams, performing qualified searches and checks.
Mr. Komaritsky has served clients in prominent international public companies focused in the pharmaceutical, digital technology, financial services, and energy fields. He holds a law degree from Moscow State University and a Master of Laws from Columbia University School of Law. He is admitted to practice law in Russia, New York and Connecticut. He is fluent in both English and Russian.
Experience
Representative Commercial Litigation Matters
- Conducted and managed E-discovery for various multinational pharmaceutical, insurance, medical device manufacturing companies, hedge funds and software companies in multi-district litigations, DOJ investigations and commercial litigations
- Prepared discovery requests and pleadings for security software company in a complex commercial litigation
- Represented defendant in the multi-billion corporate control dispute over senior care operator, including participation in the 10 day trial in the New York Supreme Court
- Developed lawsuit database for syndicate of insurance companies in COVID-19 litigation
- Conducted legal research, draft briefs, memoranda, search terms, and document review protocols in the Gadolinium-Based Contrast Agents Products Liability Litigation
Representative White Collar Matters
- Represented a multinational pharmaceutical corporation in DOJ investigation of potential FCPA violations in connection with the government tender for a vaccine in Russia
- Represented a defendant who pled guilty in the EDNY to a Medicaid/Medicare fraud scheme
- Investigated IT consulting company’s operations in India in relation to vendor padding and government bribery allegations
- Conducted internal investigation for a welding manufacturer in relation to OFAC sanctions violations
- Investigated fraud allegations in Indonesian branch of a U.S. pharmaceutical company related to misappropriation of discount cards
- Investigated whistleblower allegations regarding misuse of oncology patient assistance programs in Russian branch of a multinational pharmaceutical company
- Investigated allegations of potential off-label promotion of products by consultants of a U.S. pharmaceutical company in the Philippines and South Korea
- Investigated allegations of misappropriation of marketing budget by the country manager of a global healthcare company in Mongolia
- Investigated alleged misuse of product samples and forgery of internal corporate documents by employees of a multinational pharmaceutical company in the Philippines
- Represented a global healthcare company in a SEC investigation of potential FCPA violations in connection with government tender in Iraq
- Conducted FCPA investigation for a premier biopharmaceutical company of alleged improper payments to senior government official within the Ministry of Health of Russia in exchange for increased purchases of client’s products
- Investigated allegations of discount abuse by a government distributor of a multinational pharmaceutical company in Romania
- Investigated allegations of embezzlement by event management vendor of a multinational pharmaceutical company in Czech Republic
- Investigated alleged kickbacks by a Russian media vendor of a multinational pharmaceutical company
Representative Regulatory and Compliance Matters
- Developed and assessed FCPA/global anti-corruption compliance programs for multinational companies
- Assisted racetrack operator to obtain sports wagering license in Massachusetts
- Prepared and provided anti-bribery and anti-corruption training to employees of an international franchise company
- Participated in development of global compliance monitoring and analytics tool designed to identify key promotional risk areas for various products of a US biopharmaceutical company
- Supported a major defense and aerospace company in performing FCPA due diligence reviews on its commission sales representatives
- Counseled software company on appropriate FCPA/anti-money laundering contract provisions with business partner in UAE
- Performed anti-corruption risk and compliance audit and assessment of a multinational pharmaceutical company in Kazakhstan
Representative International Trade/Corporate Matters
- Conducted corporate/anti-corruption due diligence for financial services and digital payments company in acquisitions of cryptocurrency businesses/money management platforms
- Drafted regulatory representation and warranties clauses for sellers and buyers in M&A transactions
- Prepared regulatory due diligence reports/memoranda to clients and insurance adjusters
- Conducted compliance due diligence for worldwide distributor of medical and dental supplies in an acquisition of a U.S. medical device company
- Conducted corporate/anti-corruption due diligence for a multinational pharmaceutical company on various supply and distribution arrangements with counterparties in Russia and Kazakhstan
- Performed due diligence in M&A transactions, equity offerings and project finance, including construction of LNG plant for Kazakh oil and gas exploration group
Representative Sanctions Matters
- Represented startup companies before OFAC and the Delaware Division of Corporations with respect to Russian sanctions compliance and blockings
- Conducted due diligence on sanctions for numerous clients with business partners and customers in Russia
- Counseled venture capital fund on KYC/AML procedures including sanctions compliance and list-based screenings
- Advised a M&A buy-side party with respect to Cuban sanctions violations committed by a target software company
- Advised a publicly traded U.S. welding manufacturer on sanctions compliance, regarding several distributors and third-party vendors
- Conducted an OFAC investigation for a national franchising company related to concerns raised by the franchisee’s bank
Representative CFIUS Matters
- Performed numerous assessments of CFIUS jurisdiction in acquisitions of US businesses and real estate by foreign investors and sovereign funds
- Guided clients including but not limited to Russian venture capital fund, Israeli renewable power generation company, Chinese automaker regarding CFIUS implications of investments in U.S.
- Prepared voluntary disclosures and mandatory declarations to CFIUS for renewable energy, aerospace, aviation, financial and engineering services companies
- Represented clients in CFIUS mitigation measures, including negotiations of the National Security Agreement
News, Events, & Insights
- Navigating the U.S. Treasury Department's “Outbound Investment Rule”: International Compliance Challenges and Strategies
Insights November 18, 2024
- Agriculture & Natural Solutions Acquisition Corporation Announces US$510 Million Business Combination
News September 3, 2024
- American Resources Corporation’s American Metals LLC Announces Business Combination with Nasdaq Listed AI Transportation Acquisition Corp
News July 2, 2024
- Extensions of Russian Sanctions to Certain Imports May Not Allow Importing as Usual
Insights May 10, 2024
- APAC's Largest Cold Pressing Oil Plant Australian Oilseeds Begin Trading on Nasdaq
News March 22, 2024
- Capital A International, Owner of the Iconic AirAsia Brand, to be Publicly Listed in the U.S. through Business Combination with Aetherium Acquisition Corp
News February 29, 2024