News & Analysis as of

Department of Justice (DOJ) Due Diligence Economic Sanctions

A&O Shearman

DOJ Issues First-Ever Declination For Sanctions Violations Since Creation Of The M&A Safe Harbor Policy

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On June 16, 2024, the U.S. Department of Justice’s (“DOJ”) National Security Division (“NSD”) and the U.S. Attorney’s Office for the Southern District of Texas (“SDTX”) announced the first-ever declination to prosecute a firm...more

McDermott Will & Emery

From risk to relief: PE firm avoids prosecution with swift disclosure

In June 2025, the US Department of Justice (DOJ) announced that it declined to prosecute a private equity firm and its affiliates following the firm’s voluntary self-disclosure of criminal violations of US sanctions and...more

Paul Hastings LLP

DOJ’s M&A Safe Harbor Highlights Importance of Post-Close Due Diligence and Integration

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On June 16, the U.S. Department of Justice’s (DOJ’s or Department’s) National Security Division (NSD or Division) announced they had declined to prosecute the private equity firm White Deer Management LLC for violations of...more

The Volkov Law Group

Lessons Learned from the Unicat Settlement (Part III of III)

The Volkov Law Group on

The Unicat settlement provides some important insights into the Trump Administration’s direction on trade enforcement. It underscores the importance of voluntary disclosure, cooperation and remediation, the tri-part...more

Proskauer Rose LLP

DOJ Declination of Private Equity Firm Underscores Need for Robust M&A Due Diligence

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On June 16, 2025, the U.S. Department of Justice (“DOJ”), including its National Security Division (“NSD”) and the U.S. Attorney’s Office for the Southern District of Texas, announced that they would not prosecute White Deer...more

Morrison & Foerster LLP

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

Akin Gump Strauss Hauer & Feld LLP

Acquirors Beware: PE Firm Escapes DOJ Prosecution, but Acquired Entity Hit With $2 million+ in Penalties

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

Alston & Bird

A DOJ Private Equity Declination and Its Lessons for Acquirers and Targets

Alston & Bird on

The DOJ declined to prosecute a private equity firm for its portfolio company’s pre-acquisition sanctions and export violations, marking the first application of the National Security Division’s M&A Policy. Our White Collar,...more

Eversheds Sutherland (US) LLP

DOJ declines prosecution for PE firm after post-acquisition voluntary self-disclosure

On June 16, 2025, the Department of Justice (DOJ) National Security Division (NSD) and the US Attorney’s Office for the Southern District of Texas announced the first declination of prosecution for an acquirer that...more

American Conference Institute (ACI)

[Event] Trade & Sanctions Compliance for the Oil and Gas Industry - May 21st - 22nd, Houston, TX

Between tariffs, tightening export controls, evolving sanctions, and ramped up enforcement, the cost and complexity of compliance is rising for oil and gas supply chains. ACI’s Trade & Sanctions Compliance for the Oil and...more

Bracewell LLP

Guiding Your Company Through Trump’s New Latin America Enforcement Policy

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Shortly after President Trump’s second inauguration, his executive branch took steps to further one of his signature promises: securing the southern border. While these actions primarily impact immigration laws, several...more

The Volkov Law Group

President Biden Issues Executive Order Concerning Bulk Data, With Parallels to Current Sanctions Regulations

The Volkov Law Group on

On February 28, 2024, President Biden issued a new Executive Order in order to better secure the private data of U.S. citizens from being exploited by foreign adversaries of the United States.  By issuing his Executive Order...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - April 2023 - OFAC Enforcement Trends – Lack of Due Diligence in Mergers and Acquisitions

With roughly 12,000 names now associated with the Specially Designated Nationals and Blocked Persons List (“SDN”), layered sanctions on activities with Russia, and growing sanctions on China activities, U.S. sanctions have...more

American Conference Institute (ACI)

Compliance measures to address sanctions enforcement: ‘the new FCPA’

In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more

K2 Integrity

Sanctions Against Russia: Understanding the Evolving Picture and How to Respond

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...Since the start of the invasion of Ukraine by Russian forces on February 24, the United States (U.S.), United Kingdom (UK), and the European Union (EU) have led a global sanctions campaign against Russia that has been...more

K2 Integrity

Transaction Monitoring and Risk Mitigation Strategies for Global Supply Chains

K2 Integrity on

Between export bans and the numerous entities and individuals now restricted from transacting in the global economy, organizations worldwide must evaluate the legal, reputational, and cybersecurity impacts on their supply...more

WilmerHale

OFAC Enforcement Actions Highlight Risks to Software Providers & MSBs

WilmerHale on

On April 29, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies over their apparent violations of its regulations. The...more

Womble Bond Dickinson

Key Developments in US Sanctions

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Global supply chains have been greatly disrupted by the COVID-19 pandemic, sending companies scrambling to find both new sources of supplies and new customers for their products. But even as businesses struggle to find their...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - October 2017

ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more

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