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Department of Justice (DOJ) Corruption Economic Sanctions

Torres Trade Law, PLLC

DOJ Memoranda Impact FCPA, FARA, and Other National Security Enforcement Priorities

President Trump’s pick for Attorney General, Pam Bondi, took quick action upon her swearing in on February 5, 2025, to make changes within the Department of Justice (“DOJ”) via the issuance of fourteen separate memorandum...more

Guidepost Solutions LLC

Mexican Cartels as Foreign Terrorist Organizations: A New Era of Risk for Global Businesses

On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” This directive instructs the...more

Adams & Reese

International Compliance Digest - September 2024

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New export controls, new section 301 duties, new OFAC requirements, new de minimis rule, new DOJ corporate compliance guidance, new international guidance on Russian sanctions. September had it all....more

Adams & Reese

International Compliance Digest – August 2024

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August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more

The Volkov Law Group

DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations

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As DOJ, OFAC and BIS ramp up sanctions and export controls enforcement, they have continued to provide important compliance guidance.  You have to give the enforcement agencies credit — on the one hand, they regularly warn of...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

The Volkov Law Group

Preparing for the Storm — Effective Compliance in the New Sanctions Era (Part II of II)

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If companies operated with perfect governance mechanisms and controls, they would all be ready for the coming sanctions enforcement storm.  However, that is not the corporate reality.  Even after several companies are the...more

The Volkov Law Group

The Coming Corporate Sanctions Enforcement Storm (Part I of II)

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There are some things you learn best in calm, and some in storm.  Willa Cather I know I sound like a broken record.  The Justice Department’s white collar criminal enforcement  has been trending down over the last few...more

The Volkov Law Group

2023 Sanctions Year in Review and Predictions

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As always, I tend to repeat myself.  However, one important point needs to be repeated — DOJ is in the midst of launching an aggressive sanctions and export control program against corporations and individuals.  DOJ has...more

The Volkov Law Group

DOJ Repeats Warnings on Aggressive Criminal Enforcement of Sanctions and Export Controls

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As everyone knows, I tend to repeat myself — DOJ does as well.  Over the past year, DOJ has warned global companies — over and over — about the coming criminal enforcement storm against companies for sanctions and export...more

The Volkov Law Group

Swedbank Latvia Settles with OFAC for $3.43 Million for Crimea Sanctions Violations

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OFAC continues its enforcement push.  At the same time, OFAC is managing a complex, global set of sanctions against Russia.  DOJ has promised to increase prosecution of global banks for sanctions violations....more

The Volkov Law Group

DOJ Flexes Enforcement Muscle to Target Viktor Vekselberg, a Russian Oligarch and Co-Conspirator Assisting in Evasion of Russia...

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I am sticking with my 2023 prediction – DOJ is committed to aggressive enforcement of the Russia sanctions.  Most of its efforts to date have been directed against Russian Oligarchs and significant evaders who are moving...more

The Volkov Law Group

DOJ Charges Russian and British Businessmen for Facilitating Sanctions Evasion of Russian Oligarch’s $90 Million Yacht

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DOJ is poised for a big year in the enforcement of Russian Sanctions and seizure of assets connected to Russian Oligarchs.  It has been nearly a year since the U.S., its allies and partners have unleashed robust sanctions...more

Guidepost Solutions LLC

Focus on Foreign Banks’ Sanctions Compliance Programs in the U.S. and Globally - Upgrading and Empowering Compliance to Help...

As the Russia – Ukraine war rages on, one outcome so far is clear: the Western nations remain aligned and united to confront Russian aggression. The West’s synchronized, roll-out of economic and trade sanctions against...more

The Volkov Law Group

Navigating DOJ and OFAC Voluntary Disclosures for Sanctions Violations

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The Department of Justice is pushing its commitment to voluntary disclosure programs.  Companies, however, are not lining up at DOJ’s door.  The balance between sitting tight or voluntary disclosures requires care....more

K2 Integrity

Sanctions Against Russia: Recent Developments - October 2022

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K2 Integrity delivers information and analysis on recent developments related to sanctions against Russia and key implications for the public, private, and non-profit sectors as the United States (U.S.), the European Union...more

The Volkov Law Group

Sanctions Enforcement: “The New FCPA”

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Hold onto your hats – while we are on the cusp of more FCPA enforcement actions, the Justice Department and OFAC are gearing up for real and significant sanctions enforcement actions.  The dye is cast, so here we go. ...more

K2 Integrity

Sanctions Against Russia: The Week in Review - April 2022 - 3

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The Week in Review delivers the impact and analysis for the public, private, and non-profit sectors from our regular reporting of the evolving global sanctions campaign against Russia. This week, we reviewed the recent...more

Torres Trade Law, PLLC

Trade Enforcement Digest - January 2022

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Civil and criminal penalties levied against U.S. companies for trade violations are just the beginning of the potential unforeseen costs of doing business in the global marketplace. What cannot be quantified are the countless...more

The Volkov Law Group

2022 OFAC and Sanctions Enforcement Predictions

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The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been a steady performer in this challenging pandemic environment.  Since the pandemic, OFAC has maintained a strong profile, while managing a difficult...more

The Volkov Law Group

SAP’s Comprehensive Export Control and Sanctions Settlement – A New Compliance Frontier for Cloud-Based Services (Part III of IV)

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The Justice Department’s National Security Division used the SAP comprehensive settlement of export control and sanctions violations to send a message – a loud and clear one....more

The Volkov Law Group

SAP’s Export Control and Sanctions Failures Results in Numerous Violations of Iran Sanctions Program (Part II of IV)

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When reviewing factual reports of global corporate failures – be it FCPA, sanctions, export controls, or anti-money laundering schemes and systemic misconduct schemes – the story appears to follow a familiar pattern....more

The Volkov Law Group

SAP Reaches Broad Settlement and Agrees to Pay More Than $8 Million for Violations of Iran Sanctions Program (Part I of IV)

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In a precedent-setting agreement, the Justice Department, OFAC and the Bureau of Industry and Security announced a settlement with SAP SE for more than $8 million for numerous violations of the Iran Sanctions program....more

The Volkov Law Group

DOJ and OFAC Settle with Indonesian Company for $2.5 Million for Violations of the North Korea Sanctions Program

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PT Bukit Muria Jaya (BMJ), a global supplier of cigarette paper based in Indonesia, agreed to pay $1,561,570 for conspiracy to commit bank fraud as part of a scheme to deceive various banks in order to collect payments for...more

The Volkov Law Group

DOJ and OFAC Settle with UAE Company for $665,112 for Violations of North Korea Sanctions

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The Justice Department and OFAC announced a settlement with Essentra FZE Company Limited (“Essentra FZE”), a cigarette filter and tear tape manufacturer, for violation of the North Korea Sanctions Program.  The violations...more

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