News & Analysis as of

Criminal Prosecution International Emergency Economic Powers Act (IEEPA)

Morrison & Foerster LLP

DOJ Deploys Specialized Criminal Unit to Target Tariff Evaders

The United States Department of Justice (DOJ) has deployed its Market Integrity and Major Frauds Unit to target tariff evasion, a clear sign of the escalation of trade enforcement. The Criminal Division’s specialized unit,...more

Sheppard Mullin Richter & Hampton LLP

Department of Justice Tariff Enforcement Likely to Surge After Tariff Increases and the Administration’s Increased Focus on...

A serious step up in civil and criminal enforcement of customs laws, including tariff evasion, is imminent. In a May 12 memorandum, the Department of Justice’s new Chief of the Criminal Division, Matthew Galeotti, counted as...more

Morrison & Foerster LLP

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

Vinson & Elkins LLP

The Trump Tariff Regime Brings Risks of Criminal and Civil False Claims Act Enforcement

Vinson & Elkins LLP on

On April 2, 2025, President Donald Trump announced a new tariff regime under the International Emergency Economic Powers Act of 1977 (“IEEPA”), citing national security concerns. This regime includes a 10 percent baseline...more

WilmerHale

Implications of EO 14157 and Recent “Foreign Terrorist Organization” and “Specially Designated Global Terrorist” Designations

WilmerHale on

On January 20, 2025, President Donald J. Trump signed Executive Order 14157, “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists” (EO 14157)....more

Cooley LLP

Tariffs Are Here – Be Aware of Criminal and Civil Enforcement Risks

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On April 2, 2025, President Donald Trump, citing national security concerns, used authority granted under the International Emergency Economic Powers Act of 1977 (IEEPA) to announce a sweeping new tariff regime, with a 10%...more

Bracewell LLP

Trump Administration Efforts to Eliminate Cartels Pose Heightened Risk for Financial Institutions

Bracewell LLP on

As discussed in Bracewell’s February 11 and February 26 updates, the executive branch is prioritizing the “total elimination” of cartels and transnational criminal organizations, both through edicts from the Oval Office and...more

Foley & Lardner LLP

What Every Multinational Company Needs to Know About … Criminal Enforcement of Trade, Import, and Tariff Rules: A Growing Risk for...

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In less than 100 days, the Trump administration has implemented a dizzying array of new tariffs, significantly increasing costs and complexity for U.S. importers. The administration is keenly aware that companies operating in...more

Latham & Watkins LLP

Trump Administration Targets Cartels With First Wave of Terrorism Designations

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The designations expand US tools and jurisdictional reach, and raise the stakes for foreign financial institutions and non-US companies to avoid dealing with designated entities....more

Dorsey & Whitney LLP

Attorney General Bondi Reorients National Security Enforcement Resources to Focus on Illegal Immigration and Drug Trafficking

Dorsey & Whitney LLP on

Upon being sworn in on February 5, 2025, Attorney General Pamela Bondi immediately issued memoranda reorienting national security enforcement resources of the U.S. Department of Justice (“DOJ”) to focus on addressing illegal...more

The Volkov Law Group

New FCPA Guidance — What to Expect (Part IV of V)

The Volkov Law Group on

As we continue through the maze of Executive Orders and new Guidance, which is expected in 180 days, the questions surrounding FCPA enforcement are swirling.  In some respects, we have had a preview.  It is hard to know what...more

Foley Hoag LLP - White Collar Law &...

AG Bondi Overhauls FCPA Enforcement in Day 1 Memo

On February 5, 2025, on her first day in office, U.S. Attorney General Pam Bondi issued fourteen memos outlining new policies for the U.S. Department of Justice (“DOJ”) in a broad range of enforcement arenas. Among these Day...more

The Volkov Law Group

DOJ Reaches Groundbreaking Criminal Settlement with Cryptocurrency Exchange Binance and CEO Changpeng Zhao (Part I of III)

The Volkov Law Group on

On November 21, 2023, The U.S. Department of Justice (“DOJ”) announced settlement agreements with Binance Holdings Limited (“Binance”), the world’s largest cryptocurrency exchange, and Changpeng Zhao (affectionally known as...more

Troutman Pepper Locke

Understanding the DOJ’s Groundbreaking $4.3B Settlement with Foreign Cryptocurrency Exchange Binance.com

Troutman Pepper Locke on

On November 21, the U.S. Department of Justice (DOJ) unsealed its criminal indictment against Binance.com (Binance), the world’s largest cryptocurrency exchange, and its CEO, Changpeng “CZ” Zhao (CZ). The indictment against...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – August 2023 Update

Bass, Berry & Sims PLC on

August saw two noteworthy Russia-related enforcement actions. First, a dual Russian-German national was arrested and charged with violating the Export Control Reform Act (ECRA) when he allegedly procured microelectronics for...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – January 2023

Russia - Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating U.S. Sanctions on Russia (DOJ) Those involved. Charles McGonigal, former Special Agent in Charge of the FBI...more

Ballard Spahr LLP

Turkey’s Majority State-Owned Halkbank Is Not Immune from U.S. Prosecution in Iran Sanctions and Money Laundering Case

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Court Rejects Halkbank’s Claim That the Foreign Sovereign Immunities Act Shields the Bank From Prosecution - A motion to dismiss an indictment accusing Turkey’s majority state-owned Halkbank of money laundering, bank...more

Society of Corporate Compliance and Ethics...

US charges two Iranian nationals with sanctions violations

Report on Supply Chain Compliance 3, no. 10 (May 14, 2020) - The U.S. government charged two men with conspiring to launder money into the United States in order to purchase a Greek-owned ship to transport petroleum out...more

Society of Corporate Compliance and Ethics...

US charges blockchain specialist; China designates US nonprofits

CEP Magazine (February 2020)  - Virgil Griffith, an American citizen, was arrested Nov. 30 after speaking on blockchain solutions at the April 2019 Pyongyang Blockchain and Cryptocurrency Conference in North Korea....more

Ballard Spahr LLP

Federal Court Makes Clear That International Financial Institution Must Appear for Arraignment in Criminal Action

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Court Rejects Attempt by Halkbank to Enter “Special Appearance” Contesting Jurisdiction - Turkish state-owned bank Halkbank’s efforts to avoid appearing in U.S. federal court for arraignment were squashed recently in a...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - August 2019

ANTICORRUPTION DEVELOPMENTS - Telecommunications Company Fined $12 Million for FCPA Violations - On August 29, 2019, The Securities and Exchange Commission (SEC) instituted ceaseand-desist proceedings against...more

The Volkov Law Group

DOJ and OFAC Announce Another Sanctions Settlement – UniCredit Group Banks Pay Over $1.3 Billion and Subsidiary Bank Agrees to...

The Volkov Law Group on

The Justice Department and the Treasury Department’s Office of Foreign Asset Control (OFAC) are on a roll. Global banks are facing renewed prosecutions, along with aggressive sanctions prosecutions of companies for...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Arabic

ANTICORRUPTION DEVELOPMENTS - SEC Proposes Amendments to Whistleblower Award Program - On June 28, 2018, the Securities and Exchange Commission (SEC) proposed amendments to its whistleblower award process for the first...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Spanish

ANTICORRUPTION DEVELOPMENTS - SEC Proposes Amendments to Whistleblower Award Program - On June 28, 2018, the Securities and Exchange Commission (SEC) proposed amendments to its whistleblower award process for the first...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS - SEC Proposes Amendments to Whistleblower Award Program - On June 28, 2018, the Securities and Exchange Commission (SEC) proposed amendments to its whistleblower award process for the first...more

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