Client Results
& Testimonials

A major UAE-based financial institution facing an OFAC enforcement action alleging multiple violations of the Iran Transactions and Sanctions Regulations retained Dr. Morgan. After conducting an extensive internal investigation, self-reporting additional violations discovered during the process, and preparing a comprehensive voluntary disclosure, the matter was resolved with no civil monetary penalty — one of the most favorable OFAC outcomes achievable for an institution of this scale.

Represented the acquirer in an $850 million cross-border acquisition of a Gulf-based energy infrastructure group by a US strategic buyer. The transaction required simultaneous navigation of CFIUS review, OFAC due diligence, and UAE FDI approval. Novel structuring satisfied US export control restrictions while preserving commercial value. Full regulatory clearance was obtained within the projected timeline, enabling closing without material restructuring or price adjustment.

A DIFC-registered private equity fund held a minority equity interest in a portfolio company that became subject to OFAC blocking following a new SDN designation. Dr. Morgan prepared and submitted a specific license application documenting the fund's passive investment posture. OFAC granted the specific license within 75 days, enabling the fund to complete a compliant exit and avoid permanent asset blockage — capital successfully repatriated.

Advised a New York-headquartered alternative asset management firm on the establishment of a DIFC-licensed investment manager entity to serve GCC institutional clients. The engagement required navigating DFSA Category 3C authorization, beneficial ownership disclosures, and ADGM fund passporting. The entity received its DFSA license within six months — ahead of the firm's target date for launching its UAE-domiciled fund product.

Retained by a rapidly growing UAE fintech company following a UAE Central Bank examination identifying significant gaps in AML transaction monitoring and suspicious activity reporting. Dr. Morgan coordinated a comprehensive remediation program spanning technology, policies, training, and board governance, managing the company's regulator engagement throughout. The Central Bank closed the examination without issuing a formal consent order or imposing penalties.

Represented a UAE trading company in a Bureau of Industry and Security investigation into alleged violations of the Export Administration Regulations involving re-exports of US-origin controlled items through the UAE. After a privileged internal investigation and voluntary self-disclosure, BIS closed the matter without initiating formal administrative charges — citing the company's cooperation, self-disclosure, and comprehensive compliance program enhancements.