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Image: Sam Kleiner

Sam Kleiner

Partner, Litigation Department

New York

Phone: +1-212-318-6232
Fax: +1-212-752-3772

Overview

Sam Kleiner is a partner in the Investigations & White Collar Defense practice in the New York office. An experienced litigator, Sam represents clients in a wide range of sensitive criminal, regulatory and complex commercial litigation matters, particularly on behalf of financial institutions, drawing on his experience in senior legal positions at the U.S. Department of the Treasury and the White House.

Sam’s practice spans regulatory enforcement defense, white-collar criminal defense and compliance counseling. Clients turn to him to navigate criminal investigations, regulatory enforcement actions, civil litigation and congressional scrutiny — often at the same time. He regularly represents industry-leading banks, fintech companies, investment funds, technology companies, and their boards of directors, on complex matters implicating economic sanctions, anti-money laundering (AML), the Bank Secrecy Act (BSA) and data privacy matters. His litigation practice includes high-stakes securities and complex commercial matters in federal and state courts, with significant experience in matters involving cross-border aspects. 

A member of the firm’s Sanctions and Anti-Money Laundering group, Sam is a leading authority on sanctions and AML issues. Clients benefit from his service at the U.S. Department of the Treasury as a senior advisor in the Office of the General Counsel, the Office of the Under Secretary for Terrorism and Financial Intelligence, the Treasury component that oversees the Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN). At Treasury, he coordinated significant policy initiatives and rulemakings. He worked closely with the Department of Justice (including the National Security Division and Civil Division) on coordinating enforcement matters and significant litigation matters. His portfolio also includes the Department’s response to congressional investigations. Secretary Janet Yellen awarded him the Treasury Department’s Exceptional Service Medal. Sam serves as vice chair of the American Bar Association’s International Anti-Money Laundering Committee, serves on Law360’s banking editorial board and has been a term member of the Council on Foreign Relations. He regularly provides training to financial institutions’ legal and compliance departments, and advises trade associations on regulatory developments. 

Sam previously served as a senior deputy associate counsel at the White House, where he advised senior White House leadership on sensitive legal and congressional matters, and as a law clerk to the Honorable Gerard E. Lynch of the U.S. Court of Appeals for the 2nd Circuit. 

Sam is also the author of The Flying Tigers: The Untold Story of the American Pilots Who Waged a Secret War Against Japan (Penguin Random House), a national bestseller about the American volunteer pilots who were covertly recruited to defend China before the United States entered World War II. The book was inspired by his grandfather’s wartime service and received praise in national media including The Wall Street Journal and CNN.

Accolades

  • Treasury Exceptional Service Medal, U.S. Department of the Treasury

Education

  • Yale Law School, J.D.
  • University of Oxford, D.Phil (Marshall Scholar)
  • Northwestern University, B.A. (cum laude, Phi Beta Kappa)

Representations

  • TD Bank in a number of significant matters, including its resolutions with the U.S. Department of Justice (DOJ) over the bank’s compliance with AML requirements as part of the bank’s global resolution with U.S. government and regulatory authorities.
  • A U.S. fintech company in DOJ and other agency investigations regarding alleged anti-money laundering and sanctions violations.
  • A major global financial services institution in a DOJ sanctions investigation, including concerning Russia-, Belarus- and Ukraine-related sanctions matters.

*Matters may have been completed before joining Paul Hastings.

Engagement & Publications

Publications

  • “US Targeting TCO’s Role in Scam Centers,” Corporate Compliance Insights, Co-Author (March 31, 2026) 
  • “The State of OFAC Sanctions Enforcement in 2025-26,” Corporate Compliance Insights, Co-Author (March 16, 2026)
  • “2 OFAC Sanctions Actions Highlight PE Compliance Risk,” Law360, Co-Author (Jan. 15, 2026)
  • “Fraud, MiCA and Shadow Banking: Compliance in 2026,” MoneyLaundering.com, Contributor (Dec. 29, 2025)
  • “Lessons From Crackdown On Mexican Banks With Cartel Ties,” Law360, Co-Author (July 22, 2025)
  • “DOJ Data Security Rule Has Ticking Clock for Companies to Comply,” Bloomberg Law, Co-Author (May 20, 2025)
  • “How to Navigate Risks for Firms on Cartel-Related Activities,” Bloomberg Law, Co-Author (June 5, 2025) 
  • The Flying Tigers: The Untold Story of the American Pilots Who Waged a Secret War Against Japan, Author (2018)    

Speaking Engagements

  • “Waves of Change: The Global State of AML Regulation,” American Bar Association 2026 International Law Section Annual Conference, Panelist (May 13, 2026)
  • “Resolving Ethical Dilemmas in the Context of Sanctions Compliance Decision-Making,” AACI’s 16th Annual AML & Sanctions Compliance for the Insurance Industry Conference, Panelist (March 4, 2026)
  • “Bridging the Communication Gap Between Law Enforcement and Financial Institutions,” 22nd Puerto Rican Symposium on Anti-Money Laundering, Panelist (Feb. 27, 2026)
  • “What’s New Under the New Administration – Sanctions Update,” Institute of International Bankers’ 2025 Financial Crimes Conference, Moderator (Sept. 9, 2025)
  • “Making Sense of the AML Regulations & the Art Market,” Center for Art Law, Panelist (May 15, 2025)
  • “We’re Not Done with Beneficial Ownership! An Overview of the Latest Risks and Concerns,” American Bar Association Financial Crimes Enforcement Conference, Panelist (Oct. 8, 2024)
  • “Financial Services and Economic Statecraft,” National Security, Sanctions and Export Controls: Compliance, Investigations and Enforcement Conference, Panelist (May 23, 2024)

Involvement

  • Banking Editorial Board – Law360 Editorial Advisory Board (2026) 
  • Vice Chair of the International Anti-Money Laundering Committee – American Bar Association (2025)
  • Advisory Committee Member – United Jewish Appeal of New York 

Languages

English


Admissions

New York Bar


Education

Yale Law School, J.D. 2015

University of Oxford, Ph.D. 2012

Northwestern University, B.A. 2009