Robert M. Appleton

An internationally renowned leader in high-profile, cross-border cases – focusing on OFAC Sanctions, CFIUS, the FCPA, and global asset recovery and due diligence – Robert Appleton advises and defends international and U.S. companies, organizations and individuals in sensitive government investigations, before US regulatory bodies and criminal litigation. Robert is a highly accomplished OFAC Sanctions leader and focuses on recent Russia and China sanctions.

Robert is known for his skill in assisting clients with complex cross-border international challenges and potential issues with U.S. regulators – US Treasury Department (OFAC), Department of Commerce (DOC), Bureau of Industry & Security (BIS), Department of Justice (DOJ) and Securities and Exchange Commission (SEC). Robert has steep OFAC Treasury sanctions experience and regularly represents clients before the DOJ, the US Treasury Department, Commerce and the SEC. Robert routinely represents clients to gain CFIUS approvals for “covered” transactions and regularly makes and supports CFIUS filings on behalf of clients in consultation with the Olshan M&A team.

Robert is a world-renowned leader in the Foreign Corrupt Practices Act (FCPA), complex international fraud, and anti-money laundering investigations and defense, and leverages his many years in the US Department of Justice leading some of the most significant sanctions cases of the time as well as serving as resource to the National Security Section of the DOJ on sanctions cases throughout the country, to representing clients on OFAC and BIS matters in the present day. Robert now focuses on Russia, China and Iran sanctions issues and submitting applications for Special Licenses with OFAC to address sanctions restrictions.

Robert also has a vibrant practice representing clients in global asset recovery, cryptocurrency fraud and recovery. In the last two years, Robert has handled a number of high-profile cryptocurrency fraud matters, pursued recoveries for clients in fraud schemes and engages with law enforcement on behalf of clients in appropriate cases.

Robert’s experience extends to deep cross-border due diligence of third parties, securities and financial investigations, and whistleblower cases. Robert has led, supervised or managed more than 1,000 prominent corruption scandal, complex cross-border fraud and compliance cases spanning 150 countries, successfully retrieving more than one billion dollars in stolen assets for clients. Recently, Robert has focused on helping clients navigate the current complex web of the Russian and Chinese sanctions environment. Robert has also assisted Latin America-based financial institutions and asset management organizations in recovering funds in the U.S. and abroad, including in the Lava Jato (“Car Wash”) scandal.

With unparalleled and extensive cross-border work, steep experience in OFAC sanctions, CFIUS, FCPA, and AML investigations and defense, and having held senior positions in the U.S. government and the United Nations, Robert maintains strong and effective working relationships with senior government officials at the DOJ, Treasury, and the SEC. Robert solves problems that other lawyers cannot. This experience and his focus on consistently placing clients' goals and needs above all else are invaluable in moving cases forward that might otherwise languish without such an extensive resume. Despite his work's intense nature and complexity, clients praise the ease of working with Robert and his ability to achieve the many successes on their behalf where others may have stumbled.

Robert has held many prominent positions in government and international organizations, including serving more than 13 years as a senior U.S. federal prosecutor in the Department of Justice. Robert served as a leading OFAC prosecutor during his tenure in the DOJ, handling many high-profile sanctions cases and serving as a resource for the DOJ in cases across the country. He twice received the DOJ's prestigious Director's Award during his tenure. He served in leading enforcement, chief compliance and legal roles in several international organizations and NGOs, including at the United Nations as chief of the first Anti-Corruption Task Force.

Robert was also lead prosecutor in the DOJ’s case against Pablo Escobar’s principal money launderer, Jose Stroh, and was appointed special counsel and then lead investigations counsel to former Chairman of the Federal Reserve Paul Volcker's Independent Inquiry Committee Investigation into the Iraqi Oil for Food investigation, where he worked closely with Mr. Volcker and supervised the investigations of Saddam Hussein's corruption of the program. At the Global Fund to Fight AIDS, Tuberculosis and Malaria, Robert served as Director of Financial Investigations and Forensic Audit Deputy Inspector General. In private practice, Robert continues to represent clients in noteworthy national and international cases, investigations and cross-border matters.

  • Successfully overturned a ruling of inadmissibility by US Customs & Border Protection of client seeking to enter the US from Canada and expelled after a search. The Protest of the Expulsion was successful and DHS rescinded the order and reversed its determination at the Border.
  • Successfully represented clients seeking to unfreeze assets and monies at international financial institutions as a result of OFAC Russia Sanctions.
  • Successfully represented a client seeking CFIUS approval for a purchase of a US entity by a foreign company. CFIUS approved the application prepared and submitted by RMA who navigated the CFIUS process beginning to end.
Criminal Cases
  • Successfully represented two Brazilians in the Lava Jato cross-border FCPA prosecution led by the Department of Justice in Brazil from 2018 to the present. Succeeded in negotiating a favorable resolution for the clients that saved them from jail time and substantial penalties.
  • Represented a Canadian individual and company in a UN-related prosecution by the DOJ in the Northern District of California. His brief on UN immunity resulted in a dismissal of the charges in the case.  US v. Siciliano (N.D. California).
  • Successfully represented an SEC whistleblower in a cross-border FCPA case.
  • Engaged in one of the first cryptocurrency fraud cases in the bankruptcy courts where the crypto exchange went into bankruptcy. He represented fraud victims of the bankrupt exchange and also a money manager that defrauded numerous clients of more than $1 billion in assets.
  • Represented more than ten companies and at least seven individuals facing federal regulatory investigations and successfully persuaded the DOJ and the SEC not to charge them.
  • Succeeded in referring more than five matters to federal criminal and regulatory authorities who accepted the case, prioritizing the matters after months of self-referrals languishing in the various reporting portal systems.


Speaking Engagements

A pivotal event exploring the aftermath of the wide ranging Lava Jato enforcement actions in Brazil and featuring authorities who were centrally involved in investigating that historic scandal.


Honors & Recognitions

  • Fellow of the prestigious Litigation Counsel of America, an invitation-only trial lawyers’ honorary society. Membership is limited to 3,500 fellows, representing less than one-half of one percent of American lawyers
  • Received more than 20 awards from the U.S. Department of Justice and related agencies, including twice receiving the highly coveted Attorney General's Award for Distinguished Service, the second-highest award given in the DOJ


  • Litigation Counsel of America
  • National Trial Lawyers Association

Blog Posts


J.D., magna cum laude, Western New England School of Law, 1989

B.A., cum laude, Emory University, 1985


  • New York
  • Connecticut
  • U.S. Supreme Court
  • U.S. Court of Appeals for the Second Circuit
  • U.S. District Court for the Eastern District of New York
  • U.S. District Court for the Southern District of New York
  • U.S. District Court for the District of Connecticut
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