Key Points - On May 21, 2024, the DOJ announced its first ever declination under the NSD’s updated Enforcement Policy, declining to prosecute Sigma-Aldrich Inc., d/b/a MilliporeSigma (a subsidiary of Merck KGaA, Darmstadt,...more
6/7/2024
/ Bureau of Industry and Security (BIS) ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Enforcement ,
Export Controls ,
Incentives ,
National Security ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes
On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more
8/7/2023
/ Anti-Corruption ,
Bureau of Industry and Security (BIS) ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Export Controls ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure
Key Points -
On March 30, 2023, OFAC announced a settlement agreement with Wells Fargo for 124 apparent violations of three different sanctions programs (Iran, Syria and Sudan), all related to a legacy Wachovia Bank...more
4/18/2023
/ Compliance ,
Corporate Counsel ,
Corporate Culture ,
Corporate Misconduct ,
Economic Sanctions ,
Enforcement Actions ,
Financial Transactions ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
Wells Fargo