News & Analysis as of

Due Diligence Economic Sanctions

Skadden, Arps, Slate, Meagher & Flom LLP

UK Sanctions Update: New Designations, Lowered Oil Cap and Continued Focus on Combatting Circumvention

- What is new: UK Russian sanctions were strengthened with new designations and a reduced oil price cap. The government also published its cryptoassets threat assessment, issued guidance on sanctions for non-UK businesses and...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

K&L Gates LLP

Key Takeaways: Secondary Sanctions—United Kingdom Issues Sanctions Guidance for Non-UK Businesses

K&L Gates LLP on

On 14 July 2025, the United Kingdom’s Foreign, Commonwealth and Development Office released important sanctions guidance aimed specifically at non-UK companies operating outside the United Kingdom, with a special focus on...more

K&L Gates LLP

Key Lessons: The Latest UK Office for Financial Sanctions Implementation Art Market Participants and High Value Dealers Threat...

K&L Gates LLP on

On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) released a Threat Assessment (the Assessment) targeting Art Market Participants (AMPs) and High-Value Dealers (HVDs). This follows new rules from 14...more

Baker Botts L.L.P.

Beyond the Fine: What Financial Gatekeepers Must Learn from Interactive Brokers’ OFAC Settlement

Baker Botts L.L.P. on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has significantly increased its focus on sanctions compliance for “financial gatekeepers,” including financial institutions and other firms...more

Stankie Law

Important Sanctions Compliance Lessons from OFAC’s $11.8m Settlement with Interactive Brokers

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On July 15, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement agreement with Interactive Brokers LLC (“Interactive Brokers”) violations of multiple U.S. sanctions...more

K&L Gates LLP

Key Lessons From the Latest UK Office for Financial Sanctions Implementation Art Market Participants and High Value Dealers Threat...

K&L Gates LLP on

On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) published a threat assessment (the Assessment) on compliance with UK sanctions and money laundering law for art market participants (AMPs) and high...more

Troutman Pepper Locke

M&A and Global Compliance Lessons From OFAC’s Settlement With Key Holding

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On July 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) reached a settlement with Key Holding, LLC (Key Holding) concerning its non-U.S. subsidiary’s violations of the Cuban Assets...more

Stankie Law

Revocation of Syrian Sanctions: Opportunities, Risks, and Changes under Executive Order 14312

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President Trump continued his flurry of sanctions actions with the recent revocation of the Syrian sanctions program. On June 30, 2025, President Donald Trump issued Executive Order (“EO”) 14312 “Providing for the Revocation...more

A&O Shearman

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

A&O Shearman on

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

Paul Hastings LLP on

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

Holland & Knight LLP

FinCEN Advisory Highlights Iran Sanctions Evasion Red Flags

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The U.S. Department of the Treasury's (Treasury) Financial Crimes Enforcement Network (FinCEN), published the FinCEN Advisory on the Iranian Regime's Illicit Oil Smuggling Activities, Shadow Banking Networks, and Weapons...more

Lowenstein Sandler LLP

OFAC Imposes Largest-Ever Penalty on Nonbank Financial Institution for Egregious and Sustained Sanctions Violations—a $216M...

Lowenstein Sandler LLP on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a historic $215,988,868 civil monetary penalty against GVA Capital Ltd. (GVA), a venture-capital firm registered in the Cayman Islands...more

Benesch

Pragmatic Regulatory Compliance for Global Risk

Benesch on

Geopolitical risks to supply chains are top of mind across C-suites, but few say what it means. The term “geopolitical risk” has largely become a code word for import, export, and economic sanctions compliance. ...more

Troutman Pepper Locke

US Lifts Most Sanctions on Syria

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On May 23, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License 25 (GL 25), effectively lifting most sanctions imposed under the Syrian Sanctions Regulations (SSR) (31...more

Society of Corporate Compliance and Ethics...

Compliance in the Former Soviet Central Asian Republics

Uzbekistan, Kazakhstan, Tajikistan, Turkmenistan and Kyrgyzstan were all born out of the dissolution of the Soviet Union. With large energy deposits of national gas, many global companies and their suppliers are operating...more

Foley Hoag LLP

U.S., EU, and UK Move to Ease Sanctions on Syria, but Compliance Complexity Remains

Foley Hoag LLP on

Key Takeaways: - In a sweeping policy reversal unveiled in Riyadh on May 13, 2025, President Trump pledged to lift the entire U.S. sanctions regime on Syria. - Although the Trump administration seeks quick sanctions relief...more

Health Care Compliance Association (HCCA)

Managing Sanctions Compliance

It’s not a good time to be a manufacturer of ten-foot poles. That’s because with the growing number of sanctions regimes, there are an increasing number of companies and individuals that businesses shouldn’t touch with a poll...more

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