News & Analysis as of

Department of Justice (DOJ) National Security Export Controls

Fenwick & West LLP

DOJ and BIS Flex Enforcement Priorities as U.S. Semiconductor Design Company Agrees to Guilty Plea and $140M Fine

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On July 28, 2025, the National Security Division of the U.S. Department of Justice (DOJ) and the U.S. Department of Commerce, Bureau of Industry and Security (BIS), announced parallel criminal and civil-administrative export...more

The Volkov Law Group

Cadence Design Systems Settles with DOJ and Commerce Department for Export Control Violations and Agrees to Pay $140 Million (Part...

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DOJ’s initiation of its aggressive trade enforcement strategy is quickly unfolding — and the new strategy is a real and significant threat to all companies engaged in international trade. We are no longer in the era of FCPA...more

DLA Piper

Cadence Case Signals DOJ and BIS Priorities in Export Control Compliance

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Cadence Design Systems Inc. (Cadence) simultaneously resolved criminal charges brought by the Department of Justice’s (DOJ) National Security Division (NSD) and the United States Attorney for the Northern District of...more

Foley & Lardner LLP

DOJ Enforcement Under the National Security Division’s Data Security Program

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Protecting sensitive data has never been more important. In a globalized world of advanced cyber threats, sophisticated espionage techniques, and external data monetization, increased security is crucial to safeguard...more

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

Hughes Hubbard & Reed LLP

$140M US Export Controls Enforcement Action for ‘Reason to Know, Including Awareness of a High Probability’ Violations

On July 28, the U.S. Department of Justice’s National Security Division and the Department of Commerce’s Bureau of Industry and Security (BIS) jointly announced resolutions of parallel criminal and administrative...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

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

Hogan Lovells

The NSD declines prosecution for the first time under its M&A Policy

Hogan Lovells on

On June 16, 2025, the U.S. Department of Justice (DOJ) publicly announced that it had declined to prosecute White Deer Management LLC (White Deer) and certain affiliates for violations of sanctions law and related conduct....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

Gardner Law

New DOJ Rule Restricts Deidentified Data Transfer

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No Safe Harbor: New DOJ Data Export Rule Restricts Deidentified Data Transfer - This article outlines new requirements from the Department of Justice regarding “bulk sensitive data”, including de-identified, anonymized,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Deadline Fast Approaching for Data Security Program Compliance

The Department of Justice (DOJ) implemented a new regulatory regime (Data Security Program) addressing access to, and transfer of, sensitive personal data to countries and persons of concern, including Russia, China and...more

BakerHostetler

A Refocused China Initiative: DOJ’s New White Collar Enforcement Strategy

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On May 12, 2025, Matthew Galeotti, Head of the Department of Justice’s (DOJ) Criminal Division, unveiled a comprehensive white collar enforcement strategy titled “Focus, Fairness, and Efficiency in the Fight Against...more

Wyrick Robbins Yates & Ponton LLP

The Justice Department’s New Rule on Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or...

On April 8, 2025, the Department of Justice’s new rule on Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons took effect. The rule, referred to by DOJ as the Data...more

Morrison & Foerster LLP

DOJ Issues Declination in Corporate Export Control Violations Matter

On April 30, 2025, the Department of Justice (DOJ) National Security Division (NSD) announced its second-ever public declination under its updated corporate voluntary self-disclosure (VSD) policy when it declined to charge...more

The Volkov Law Group

Voluntary Self-Disclosure Shields Universities Space Research Association from Prosecution by DOJ

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On April 30, 2025, the U.S. Department of Justice’s National Security Division (“NSD”) issued a formal declination of prosecution to the Universities Space Research Association (“USRA”) following the organization’s timely and...more

Faegre Drinker Biddle & Reath LLP

DOJ National Security Division Issues Second Declination Since Issuance of Revised Corporate Enforcement Policy

On April 30, 2025, the National Security Division (NSD) of the Department of Justice (DOJ) announced the declination of prosecution against the Universities Space Research Association (USRA), a federal government contractor,...more

WilmerHale

Voluntary Disclosure of Export Control Violations is Critical for Settling Criminal Liability, DOJ Action Shows

WilmerHale on

The Department of Justice’s (DOJ) recent announcement that it would decline to prosecute a self-reported criminal export control violation demonstrates the continuing importance of prompt, voluntary self-disclosure (VSD) and...more

Seward & Kissel LLP

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

Seward & Kissel LLP on

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

Baker Botts L.L.P.

Justice Department Declines Prosecution of U.S. Contractor for Export Control Violations of Rogue Employee

Baker Botts L.L.P. on

For only the second time under its updated voluntary self-disclosure program, the U.S. Justice Department decided not to prosecute Universities Space Research Association after the company self-disclosed criminal violations...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

Baker Donelson

DOJ Issues Additional Guidance and Clarification on the Bulk Data Transfer Rule: What U.S. Businesses Need to Know

Baker Donelson on

On April 11, 2025, the Department of Justice's National Security Division (NSD) issued additional guidance to assist U.S. organizations in understanding and complying with the Data Security Program (DSP). As discussed in our...more

Orrick, Herrington & Sutcliffe LLP

DOJ implements its Data Security Program to protect users’ data

On April 11, the DOJ announced steps towards the implementation of a national security program aimed at protecting Americans’ sensitive data from China, Russia, Iran and other foreign adversaries. The Data Security Program,...more

Mintz - Antitrust Viewpoints

Commerce Department Investigates National Security of Semiconductors, and US Attorney Indicts AI CEO for Fraud — AI: The...

On April 1, the Department of Commerce (Commerce) launched a Section 232 investigation into the national security of semiconductor imports. On April 16, Commerce published a Request for Information (RFI) seeking public...more

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