.avif)
J.D., Georgetown University Law Center
B.A., Political Science, University of California Los Angeles
New York
California
U.S. District Court for the District of Columbia (DDC)
U.S. District Court for the Southern District of New York (SDNY)
U.S. District Court for the Eastern District of New York (EDNY)
Farsi (fluent)
Sam Amir Toossi
Sam Amir Toossi is a Chambers-ranked litigator who leads Akrivis Law Group’s White Collar Defense and Commercial Litigation practice. He represents companies, financial institutions, executives, investment funds, and high-net-worth individuals in government investigations, economic sanctions matters, internal investigations, complex commercial litigation, and other high-stakes disputes. His practice is distinguished by its focus on cross-border matters where criminal, regulatory, commercial, and reputational risks intersect. His experience across government, private practice, and consulting enables him to provide clients with practical advice that reflects not only legal risk, but also the commercial, operational, and reputational considerations that frequently accompany government investigations and complex disputes.
Mr. Toossi has developed a nationally recognized practice advising clients on U.S. economic sanctions, anti-money laundering, and cross-border enforcement. His representative matters include successfully removing multiple individuals from OFAC’s Specially Designated Nationals (“SDN”) List, obtaining declinations in numerous federal criminal investigations, negotiating extraordinary resolutions in complex federal prosecutions, and representing clients in significant commercial, bankruptcy, and appellate litigation.
Mr. Toossi is ranked by Chambers and Partners in Litigation: White Collar Crime & Government Investigations. Chambers clients describe him as “highly analytical,” “solution-focused,” and “deliberate and thoughtful in his approach to litigation.” Clients further commend his ability to provide “a level of attention that gives the client a sense of comfort and confidence,” while noting that his written advocacy is “particularly thorough and impressive.”
A seasoned trial lawyer, Mr. Toossi has tried 26 cases to verdict and argued numerous appeals before state and federal courts, including the U.S. Court of Appeals for the District of Columbia Circuit. Whether defending a government investigation, litigating a sanctions designation, or pursuing complex commercial litigation, he approaches every matter with the perspective that effective advocacy requires not only exceptional legal analysis but also a deep understanding of each client’s business objectives and strategic priorities.
Before entering private practice, Mr. Toossi served as an Assistant United States Attorney for the Eastern District of New York, where he was Deputy Chief of the International Narcotics and Money Laundering Section. He supervised and prosecuted some of the Department of Justice’s most significant cross-border investigations involving money laundering, corruption, international narcotics trafficking, public corruption, healthcare fraud, and financial crime. During his tenure, he served as one of the federal prosecutors responsible for the investigation and prosecution of Joaquín “El Chapo” Guzmán, including indicting the case on which Guzmán was ultimately tried and convicted. He also served as co-lead trial counsel in the prosecution of international narcotics trafficker Jimmy Cournoyer and was a member of the trial team that secured the conviction of Gambino Crime Family consigliere Bartolomeo Vernace on racketeering charges. For his service, Mr. Toossi received the Attorney General’s Award for Exceptional Service—the Department of Justice’s highest honor—as well as the Federal Prosecutor Award from the Federal Law Enforcement Foundation.
Prior to his government service, Mr. Toossi practiced at Sullivan & Cromwell LLP, where he represented clients in white-collar matters, securities, patent, and commercial litigation. He later served as a director at PwC, leading investigations and regulatory engagements involving financial fraud, cybersecurity, professional liability, and data breaches.
Mr. Toossi is an Adjunct Professor of Law at Seton Hall University School of Law, where he teaches dispute resolution and arbitration with an emphasis on international frameworks. He is also a Fellow of the Litigation Counsel of America, an invitation-only honorary society recognizing excellence in trial advocacy.
J.D., Georgetown University Law Center
B.A., Political Science, University of California Los Angeles
New York
California
U.S. District Court for the District of Columbia (DDC)
U.S. District Court for the Southern District of New York (SDNY)
U.S. District Court for the Eastern District of New York (EDNY)
Farsi (fluent)
White Collar Defense, Government Investigations & Economic Sanctions
- Successfully represented the former Chief Executive Officer of Otkritie Bank, Mikhail Zadornov, in federal litigation challenging his designation on the U.S. Treasury Department’s Specially Designated Nationals (“SDN”) List, ultimately securing his removal from the List.
- Successfully obtained the removal of five additional individuals from OFAC’s SDN List following the imposition of Russia-related sanctions after the invasion of Ukraine, including securing the delisting of Elena Titova and Andrey Golikov, who were among the earliest individuals removed from the SDN List under the post-invasion Russia sanctions program.
- Represent the Chief Compliance Officer of a major U.S. financial institution in connection with an ongoing federal criminal investigation.
- Represented a Hungarian company in parallel investigations by the U.S. Department of Justice, Homeland Security Investigations, and the Office of Foreign Assets Control concerning alleged sanctions evasion involving Iran, culminating in the government’s decision to decline prosecution.
- Represented the target of an FBI and Department of Justice investigation into allegations of operating an unlicensed money transmitting business, resulting in the government declining criminal charges.
- Represented the president of a New York import-export company indicted on federal money laundering and structuring charges carrying a maximum sentence of twenty years’ imprisonment. Following extensive pretrial litigation, negotiated a rare resolution shortly before trial permitting the client to plead guilty to a single misdemeanor offense.
- Represented a Canadian national charged in federal court with money laundering offenses, obtaining dismissal of all criminal charges.
- Represent a UAE-based brokerage in connection with allegations of violations of U.S. economic sanctions laws.
- Represented a professional engineer in a federal investigation involving allegations of trade secret theft and sanctions violations relating to Iran, resulting in the government declining prosecution.
- Represented a licensed customs broker in a federal investigation concerning alleged tariff evasion, resulting in no criminal charges or professional disciplinary action.
Commercial Litigation & International Disputes
- Represented the judgment creditor in connection with the recognition and enforcement of a $111 million ICSID arbitration award.
- Represent a high-net-worth individual in a complex adversary proceeding pending in the U.S. Bankruptcy Court for the Southern District of New York involving claims under the Civil RICO Act, bank fraud, wire fraud, and conspiracy.
- Represented a Liechtenstein company in administrative proceedings challenging an OFAC sanctions designation and currently serve as lead appellate counsel before the U.S. Court of Appeals for the District of Columbia Circuit.
- Represent a financial technology company in the U.S. District Court for the Southern District of New York in litigation involving claims for defamation and trademark infringement.
- Represented PwC in connection with the New York Attorney General’s litigation concerning ExxonMobil’s climate-related financial disclosures.
- Obtained dismissal of all claims asserted against a New York company in litigation alleging violations of the Telephone Consumer Protection Act.
Economic Sanctions & Regulatory Compliance
- Advise dozens of companies across Europe, the Middle East, Canada, and Southeast Asia on U.S. economic sanctions, anti-money laundering compliance, export controls, and related regulatory matters, including financial institutions, manufacturers, fintech companies, family offices, trading companies, and import-export businesses.
- Regularly represent companies and individuals before the Office of Foreign Assets Control in connection with applications for specific licenses authorizing transactions otherwise prohibited under U.S. sanctions laws.
- Co-author, Practitioner’s Guide to Global Investigations – U.S. Perspective on Parallel Civil Litigation
- Panelist, presented Developments in Cryptocurrency Currency, Global Investigations Review Annual Conference, Madrid, October 2022
- Speaker, presented The Insider: Tips for Succeeding as Outside Counsel from a Former In-House Attorney, New York State Bar Association (NYSBA), New York, May 2023
- Author, Cryptocurrency and Sanctions Evasion, WorldECR, August 2022
- Contributor, Overview of Russian Economic Sanctions – Past and Present, Practising Law Institute (PLI), May 2022
