James Earl

Special Counsel, Sullivan & Cromwell

A member of the Firm’s Financial Services Group, Jamie Earl focuses his practice on economic sanctions and financial crime, with a particular emphasis on authorities administered by the Office of Foreign Assets Control (OFAC) and national security matters, including U.S. primary and secondary economic sanctions, and anti-money laundering.

Mr. Earl joined the Firm in 2018 from the U.S. Department of the Treasury, where he served for nine years in legal and policy roles with the Office of the Chief Counsel (Foreign Assets Control) and OFAC. In five years with OFAC Counsel’s office, Mr. Earl provided advice, counseling, and legal review on issues related to OFAC sanctions with respect to Iran, WMD proliferation, transnational criminal organizations, malicious cyber-enabled activities, and the Western Balkans, including policy, licensing, enforcement, and regulatory matters. Earlier in his Treasury career, he was responsible for developing policy options for using OFAC and United Nations authorities to address new and emerging threats to U.S. national security, with a focus on counter-terrorism and North Korea.

Mr. Earl also served on the National Security Council staff under two administrations as Director for Iran Nuclear Implementation. In that role, he was responsible for coordinating implementation of U.S. sanctions commitments and monitoring of Iran’s nuclear commitments under the Joint Comprehensive Plan of Action (JCPOA), which Mr. Earl helped to craft as a sanctions legal expert for the U.S. negotiating team.