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DOJ Issues First-Ever Declination Under Corporate Disclosure M&A Policy

On June 16, 2025, the Department of Justice (DOJ) National Security Division (NSD) announced that it declined to charge private equity firm White Deer Management LLC (“White Deer”) and its affiliates after the company...more

AI Diffusion Rule Out but BIS Increases Compliance Obligations for Companies

On May 13, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) announced a recission of the Biden administration’s January 15, 2025 Artificial Intelligence Diffusion Interim Final Rule (“AI Diffusion...more

Terrorism Designations Primer: Process, Authorities, and Recourse

Since the mid-1990s, the Executive Branch has sought to target foreign terrorist organizations, and those individuals and organizations supporting them, in order to degrade their funding and support. Organizations and...more

DOJ Issues Declination in Corporate Export Control Violations Matter

On April 30, 2025, the Department of Justice (DOJ) National Security Division (NSD) announced its second-ever public declination under its updated corporate voluntary self-disclosure (VSD) policy when it declined to charge...more

FTO Designations Heighten Risks for Companies Operating in Latin America / Las designaciones de FTO aumentan los riesgos para las...

Key Takeaways- • Recent Foreign Terrorist Organization (FTO) designations affecting cartels and transnational criminal organizations (TCOs) have equipped the Department of Justice (DOJ) with a powerful source of authority...more

U.S. Sanctions Enforcement: 2024 Lessons Learned and 2025 Expectations

As the third month of the second Trump administration comes to a close, the lack of any public enforcement action by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctions watchers...more

Key Points from the 2023 CFIUS Annual Report

On July 23, 2024, the Committee on Foreign Investment in the United States (CFIUS or the “Committee”) released its Annual Report to Congress covering calendar year 2023. In a year that featured lower deal volume, CFIUS...more

OFAC Year in Review 2023 – Part 1

2023 was another record year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Most prominently, OFAC continued to impose significant additional sanctions on Russia in...more

U.S. Sanctions Enforcement: 2022 Trends and Lessons Learned

Today’s alert—the third and final installment in our Sanctions 2022 Year in Review series—provides an overview of U.S. sanctions enforcement in 2022, including the key lessons learned from the enforcement actions issued by...more

OFAC Year in Review 2022 – Part 1

2022 was an unprecedented year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). While the sweeping new U.S. sanctions imposed against Russia and Belarus in unparalleled...more

New CFIUS Enforcement Guidelines Signal Expanded Compliance Focus

In what likely portends enforcement actions in the near future, the U.S. Department of the Treasury published its first ever CFIUS Enforcement and Penalty Guidelines (the “Guidelines”)....more

Justice Department Announces Launch of Task Force “KleptoCapture” focused on Russia-related Sanctions Violations

On March 2, 2022, the U.S. Department of Justice announced the launch of Task Force KleptoCapture, an interagency law enforcement task force dedicated to enforcing the unprecedented sanctions, export, and other measures taken...more

MoForecast: Analyzing Recent Speeches Given by DOJ Leadership

In this episode of MoForecast, James Koukios, co-chair of the Securities Litigation, Enforcement, and White Collar Defense and the FCPA + Global Anti-Corruption Practice Groups, speaks with fellow MoFo partners Brandon L. Van...more

DOJ Announces Renewed Focus on Export Control and Sanctions Enforcement

In a keynote address at the Global Investigations Review Connect: New York conference on October 5, Principal Associate Deputy Attorney General John Carlin provided insights into future Department of Justice (“DOJ” or the...more

Lessons Learned From OFAC’s 2021 Enforcement Actions So Far

As peak summer holiday season approaches, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) continues to remind the private sector of the importance of strict economic sanctions compliance. OFAC...more

Lessons Learned From OFAC’s 2020 Enforcement Actions

As we previously wrote in our OFAC 2020 Year in Review, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) saw a drop in enforcement activity in 2020, likely due to the massive year it had in 2019 and...more

OFAC 2020 Year In Review

In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more

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