Jan advises clients on the full spectrum of regulatory compliance and implementation and enforcement matters, including risk assessments, design and evaluation of sanctions and export control compliance programs, merges & acquisitions, contractual negotiation and reviews, transaction due diligence, licensing, internal investigations, remediation and related disputes.
Jan has particular experience with enhanced sanctions and export controls due diligence, particularly in the context of detecting and preventing circumvention risks or evaluating other high-risk projects or transactions. He has unique experience preventing sanctions violations in third countries. Jan also has experience assisting clients in connection with pre-litigation matters and disputes arising out of sanctions and export controls, including in international arbitration.
Concerning his anti-corruption practice, Jan has experience navigating the multi-jurisdictional and international aspects of compliance assessments and internal investigations. He has designed and audited compliance programs, performed internal investigations and due diligence reviews on third-party agents and joint-venture partners around the world, including in connection with the U.S. Department of Justice (DOJ), the U.S. Securities & Exchange Commission (SEC), the French Parquet National Financier (PNF) and anticorruption agency (AFA), the U.K. Serious Fraud Office (SFO), as well as multilateral development bank (MDB) and export credit agencies (ECAs) inquiries.
Jan speaks and writes extensively on subjects related to sanctions and export controls. He has been quoted and has appeared in several leading media. Jan is an Associate Fellow of the Royal United Services Institute (RUSI)’s Centre for Financial Crime and Security Studies (CFCS) and engages with the authorities in the EU on sanctions policy. He has lectured on EU sanctions at Sciences Po Law School, the European University Institute, and the Sorbonne.
Prior to founding Bennink Dunin-Wasowicz in 2024, Jan was partner and co-chair of the sanctions & export controls practice group of a New York international law firm, based in the Paris office.
French, English, German, Polish