News & Analysis as of

Department of Justice (DOJ) Enforcement Actions Economic Sanctions

Husch Blackwell LLP

DOJ Declines to Prosecute Private Equity Firm After Self-Disclosure Related to Acquired Company

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Last year, the Department of Justice (DOJ) National Security Division (NSD) updated its Enforcement Policy for Business Organizations to include guidance related to voluntary self-disclosures in connection with acquisitions....more

Morgan Lewis

FinCEN Issues First Transaction Ban on Certain Mexico-Based Financial Institutions

Morgan Lewis on

In a historic first, the US Department of the Treasury’s Financial Crimes Enforcement Network recently published orders prohibiting transactions with covered Mexico-based financial institutions. On June 30, 2025, the US...more

Wiley Rein LLP

Update: Enforcement of DOJ Data Security Program Set to Begin July 9

Wiley Rein LLP on

The U.S. Department of Justice (DOJ) is set to enforce its sweeping new rule on certain U.S. data transactions with countries of concern and covered persons as of July 9, 2025. The new rule regarding “Preventing Access to...more

The Volkov Law Group

Episode 376 -- DOJ's Unicat Settlement and the Future Look of Trade Enforcement Actions

The Volkov Law Group on

What happens when a company inherits a sanctions violation through acquisition, and acts fast to fix it? Can a robust post-acquisition response really save a parent company from prosecution? In this episode, Michael...more

Bass, Berry & Sims PLC

Sanctions Enforcement Update: DOJ Declines Prosecution After Post-Acquisition Disclosure

In June 2025, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) announced that Unicat Catalyst Technologies, LLC (Unicat), a Texas-based petrochemical company, had agreed to settle its potential civil liability...more

Blank Rome LLP

[Webinar] 180 Days of the Trump Administration—Quick Hits on Executive Orders, Actions, and Policies - July 17th - August 13th,...

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Blank Rome presents a new summer webinar series where our interdisciplinary team will unpack the most pressing legal, regulatory, and policy developments from the Trump Administration’s first 180 days. Each session offers...more

McDermott Will & Schulte

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

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

The Volkov Law Group

Unicat Settles with DOJ and Resolves Sanctions, Export Controls and Customs Violations Applying Voluntary Disclosure Policy in M&A...

The Volkov Law Group on

In an interesting enforcement action reflecting the Administration’s priority on sanctions, export and customs enforcement, DOJ announced a global resolution with DOJ, OFAC, BIS and CBP and Unicat Catalyst Technologies...more

King & Spalding

Recent OFAC and DOJ Activity Signals Potential New Era of Control-Based Sanctions Enforcement

King & Spalding on

U.S. sanctions enforcement is evolving to adopt a “control” analysis similar to the analysis employed by the European Union and United Kingdom based on a recent major enforcement action by the U.S. Department of the...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

The Volkov Law Group

OFAC Returns to Enforcement Scene — GVA Capital Pays $215 Million Penalty for Violations of Ukraine/Russia-Sanctions

The Volkov Law Group on

The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been relatively quiet on the enforcement front. That is not unusual — every transition results in an enforcement hiatus. Sanctions enforcement is a...more

White & Case LLP

DOJ Declines to Prosecute Private Equity Firm after Post-Acquisition Voluntary Self-Disclosure of Sanctions and Export Control...

White & Case LLP on

In its first application of the policy on voluntary self-disclosures (“VSDs”) in connection with mergers and acquisitions (“M&A”), on June 16, 2025, the US Department of Justice’s (“DOJ”) National Security Division (“NSD”)...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

Thomas Fox - Compliance Evangelist

2 Gurus Talk Compliance – Episode 54 – The FCPA is Back On Edition

What happens when two top compliance commentators get together? They talk compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s...more

Thomas Fox - Compliance Evangelist

10 For 10: Top Compliance Stories For the Week Ending June 14, 2025

Welcome to 10 For 10, the podcast that brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance, brings to you, the compliance professional, the compliance stories you need to...more

The Volkov Law Group

DOJ Expands Whistleblower Program to Include Tariffs, Sanctions and Export Controls (Part III of III)

The Volkov Law Group on

DOJ’s new Corporate Enforcement Program is designed to bring certainty to the voluntary disclosure and cooperation process.  DOJ’s intent is clear — voluntary disclosure is likely to lead to a declination, reduced penalties...more

Perkins Coie

DOJ Signals Renewed Prioritization of Corporate Enforcement with New Policies Regarding Voluntary Disclosure, Monitors, &...

Perkins Coie on

On May 12, 2025, Matthew R. Galeotti, the head of the DOJ’s Criminal Division, gave a speech at SIFMA’s Money Laundering and Financial Crimes Conference that previewed subsequently issued policy changes impacting the Criminal...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ White Collar Enforcement Plan Continues To Present Risks for Non-US Companies

Matthew Galeotti’s recent memorandum as head of the Department of Justice’s (DOJ’s) Criminal Division echoes the Trump administration’s “America First” priorities. It directs the Criminal Division to “strike an appropriate...more

The Volkov Law Group

This is Not the Time to Retreat on Compliance

The Volkov Law Group on

Call me an optimist — it is a much better alternative than being a pessimist or a “realist” with a pessimistic bent. So, let’s start by acknowledging the obvious. Businesses are operating in a volatile environment. The...more

DLA Piper

The Second Trump Administration’s First 100 days

DLA Piper on

The first 100 days of the second Trump Administration have been marked by a flurry of Executive Orders (EOs) and policy memoranda intended to advance President Donald Trump’s “America First” agenda. In the process, these...more

Morrison & Foerster LLP

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

Seward & Kissel LLP

DOJ Implements New Data Security Program: Data Transfer Restrictions with a National Security Focus

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Effective as of April 8, 2025, the National Security Division of the U.S. Department of Justice (DOJ) has implemented a Data Security Program (the DSP) to address national security risks associated with the transfer of...more

The Volkov Law Group

Episode 365 -- Four Sanctions Cases Everyone Should Know

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How prepared is your organization to handle the evolving landscape of sanctions compliance? In this episode of Corruption, Crime and Compliance, Michael Volkov dives into critical sanctions compliance cases and their...more

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