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About Alexander Dmitrenko

Alexander is our head of Asia sanctions. He specialises in white-collar defence, internal investigations, sanctions/export controls and dispute resolution.

Alexander has substantial experience advising companies across Asia on compliance with sanctions/export controls, anti-bribery/corruption, anti-money laundering, human rights/forced labour and other laws and regulations, including establishing compliance policies and procedures, conducting due diligence and compliance clearance on various projects and investments, and conducting internal and regulatory investigations related to potential violations (eg, of the US sanctions or the US Foreign Corrupt Practices Act).  Alexander’s practice also focuses on advising financial institutions and other clients on compliance and risk mitigation measures related to US-China regulatory tensions and a potential conflict of laws.  Alexander’s main clients represent manufacturing, trading, energy, insurance, infrastructure, telecommunications and financial/investment sectors.

He speaks English, French, Japanese, Russian and Ukrainian.

Recent work

Investigations (lead role):

Conducted over a dozen of sensitive internal and regulatory investigations covering allegations of bribery, accounting misconduct, internal violations, harassment and product liability in such jurisdictions as China, Ghana, India, Japan, Kazakhstan, Korea, Russia, United States and Vietnam, including:

  • Self-reporting and OFAC regulatory investigation of US sanctions violations, and related compliance system build-up for a multinational client in Japan.
  • Three separate internal investigations for a major accounting firm triggered by whistle-blower allegations related to bribery, accounting irregularities, breach of internal and industry rules, favouritism, etc.
  • Two separate investigations for a multinational pharmaceutical company related to the alleged misconduct and potential self-reporting in India.
  • A product liability investigation on behalf of a major Japanese trading house.
  • US Foreign Corrupt Practices Act investigation of a major Russian company and its subsidiary in Uzbekistan.

Compliance policies and advisory:

Advised over a dozen of major Japanese and Asian companies (in financial, manufacturing, insurance, trade, energy, retail and telecommunications sectors) on:

  • Establishing, enhancing and implementing global and domestic compliance programs (ABC, sanctions, export controls, AML, human rights, etc.), including policies, procedures, hotlines, and trainings.
  • Sanctions and export control compliance and risk mitigation related to the evolving US-China regulatory tensions and a potential conflict of laws.

Corporate transactions (most recent):

Conducted negotiations and drafted documentation related to various corporate transactions (financing, joint ventures, investments, guarantees, etc.) and led compliance due diligence process on over 40 projects, including advising:

  • Mitsui & Co., Ltd. on the establishment, together with Japan Oil, Gas and Metals National Corporation (JOGMEC), of investment consortium Japan Arctic LNG B.V., and subsequent acquisition by Japan Arctic LNG B.V. of a 10% participating interest in Arctic LNG 2 LLC.
  • JBIC on the JPY 65+ billion “Samurai Bond” offering by Gazprom to Japanese institutional investors.
  • Telecommunications providers across Asia with respect to ZTE- and Huawei-related export control issues, including compliance, contractual protections and potential disputes.

Qualifications

Education

  • New York University, US (LLM)
  • University of Toronto, Canada (LLM)
  • Central European University, Budapest, Hungary (LLM)
  • Southern Federal University, Rostov-on-Don, Russia

Professional qualifications

  • Law Society of England & Wales
  • New York State, US 
  • Russian Federation
  • Registered as a Gaikokuho-Jimu-Bengoshi with the Daini Tokyo Bar Association

Memberships

  • Chair, Japan Sub-Committee of Temple University Law School Advisory Board on Compliance and Ethics
  • Co-founder and co-Chair, Lawyers for LGBT & Allies Network (LLAN), Japanese NPO
  • Member, TELL Japan Board of Directors (focusing on mental health and suicide prevention), Japanese NPO
  • Friendship (Tourism) Ambassador, Island of Hachijojima

Publications

  • Routledge Chapter 8: Implementation and Enforcement of UN Sanctions—the private sector’s key role and evolving standards, United Nations Financial Sanctions

  • "New Business Law" magazine published by Shoji Homu on 1 March 2017 (Language: Japanese) The New Russian Arbitration Laws

  • “The Lawyers” magazine published by ILS Publications, Inc. on 1 December 2016 (Language: Japanese) “Business opportunities and compliance issues in Iran”

  • “The Lawyers” magazine published by ILS Publications, Inc. on 1 December 2016 (Language: Japanese) "How to deal with increased global investigation risks – be prepared for investigations in various jurisdictions"

  • Shoji Homu on 7 November 2016 (Language: Japanese) Understanding Global Investigations

  • Debevoise & Plimpton LLP's FCPA Update, Volume 6 (No. 7) in February 2015 “Compliance in a Hot Zone: Ukraine Enacts New Anti-Corruption Laws”