In March 2024, NSD issued an updated Enforcement Policy for Business Organizations (NSD Enforcement Policy) that includes the M&A Policy. Under the M&A Policy, where an acquiring company makes a qualifying voluntary...more
While media reporting has predominantly focused on the provisions in the emergency foreign aid package that President Biden signed into law on April 24, 2024 that provides funding for Ukraine, Israel and Taiwan, House Foreign...more
5/1/2024
/ Department of Justice (DOJ) ,
Drug Trafficking ,
Economic Sanctions ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
New Legislation ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Sanction Violations ,
Statute of Limitations ,
TWEA
Key Points -
On March 2, 2023, DOJ announced that its NSD would hire more than 25 new prosecutors to investigate and prosecute sanctions evasion, export controls violations and similar economic crimes. Consistent with...more
• On December 13, 2019, the Department of Justice (DOJ) revised and re-issued its “Export Controls and Sanctions Policy for Business Organizations” (the “Revised Policy”) to “provide greater clarity for companies faced with a...more
12/20/2019
/ Corporate Counsel ,
Corporate Misconduct ,
Criminal Penalties ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
Exports ,
Financial Institutions ,
Incentives ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Voluntary Disclosure
• The U.S. Department of the Treasury's Office of Foreign Assets Controls (OFAC) recently published guidance that describes the framework for an effective Sanctions Compliance Program (SCP). In its guidance, OFAC makes clear...more
5/30/2019
/ Civil Monetary Penalty ,
Compliance ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Internal Controls ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Risk Mitigation ,
Sanctions ,
Senior Managers ,
U.S. Treasury ,
Voluntary Disclosure
On October 2, 2016, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) established a formal, voluntary self-disclosure program for criminal violations of U.S. economic sanctions and export controls...more
On June 8, attorneys for the U.S. Department of Justice (DOJ) joined Dutch aerospace company Fokker Services BV (“Fokker”) in appealing the district court’s rejection of Fokker’s deferred prosecution agreement (DPA) with the...more
6/12/2015
/ Aerospace ,
Aircraft Equipment ,
Appeals ,
Burma ,
Civil Monetary Penalty ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
Exports ,
Fokker ,
Judicial Authority ,
Sanctions ,
Sudan