News & Analysis as of

Due Diligence Enforcement Actions

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

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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

Fenwick & West LLP

Washington Becomes First State to Enact ‘Mini HSR’ Notification Requirement

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As of July 27, 2025, federal Hart-Scott-Rodino (HSR) Act filings will also need to be submitted to the Washington Attorney General (WA OAG) under Washington State’s Antitrust Premerger Notification Act (APNA) if the parties...more

Baker Botts L.L.P.

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

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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

Baker Botts L.L.P.

EU Foreign Subsidies Regulation & M&A: Latest Developments and Implications for Deal Strategy

Baker Botts L.L.P. on

The European Union’s Foreign Subsidies Regulation (“FSR”) has now been in force for over a year, introducing a new layer of regulatory oversight for companies engaging in M&A transactions within the EU. Designed to address...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

The Volkov Law Group

Episode 377 -- Refocusing Due Diligence on Cartels and TCOs

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Could your supply chain be funding cartels without you realizing it? In today’s complex global economy, companies are grappling with a dual challenge - the urgent need to unravel their supply chains and the immediate...more

Morrison & Foerster LLP

The FTC Gives the Merchant of Record Model a Paddling

The Federal Trade Commission (FTC) recently settled an enforcement action with Paddle.com, a U.K.-based payments company, and its U.S. subsidiary (“Paddle”). The settlement resolves claims against Paddle for violation of the...more

Thomas Fox - Compliance Evangelist

FCPA Compliance Report: Stay the Course: Ellen Lafferty on Navigating Anti-Corruption Compliance in 2025

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Today, Tom Fox welcomes Ellen Lafferty, a well-known figure in the compliance community with a distinguished career in both...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

The Volkov Law Group

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

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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

Quarles & Brady LLP

DOJ Uses Successor Liability as a Civil Cybersecurity Enforcement Tool: Comprehensive Diligence Now May Save Millions Later

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The United States Department of Justice (DOJ) recently settled a qui tam suit with a defense contractor and its successor company for $8.4 million, resolving allegations that the contractor and successor company violated 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

DLA Piper

Private Equity Acquirer Avoids “Unicat-astrophe” Following Voluntary Disclosures to the DOJ

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The US Department of Justice (DOJ) announced that it has formally declined to prosecute private equity firm White Deer Management LLC (White Deer) and certain of its affiliates in connection with criminal violations of US...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

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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

American Conference Institute (ACI)

[Virtual Conference] EAR Compliance & Licensing Masterclass - July 14th - August 7th, 12:00 pm - 3:00 pm EDT

The Trump Administration is aiming to eliminate loopholes in the U.S. export controls system, expand the scope of the EAR, and ramp up enforcement. Get the insights you and your team need to strengthen your compliance program...more

Bennett Jones LLP

Final Guidelines from the Competition Bureau on Environmental Claims in Canada

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On June 5, 2025, the Competition Bureau (the Bureau) published its final Guidelines for environmental claims under the Competition Act (the Act). The Guidelines were created to help businesses and the public understand the...more

Foley & Lardner LLP

HIPAA Risk Analyses for Digital Health: Navigating AI, M&A and Vendor Diligence

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Share on Twitter Share by Email Share Back to top HIPAA Security Risk Analyses (SRAs) should be the foundation of every digital health company’s cybersecurity compliance. Far more than a checkbox exercise, a comprehensive SRA...more

Morrison & Foerster LLP

AI Diffusion Rule Out but BIS Increases Compliance Obligations for Companies

On May 13, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) announced a recission of the Biden administration’s January 15, 2025 Artificial Intelligence Diffusion Interim Final Rule (“AI Diffusion...more

Foley & Lardner LLP

What Every Multinational Company Should Know About … Mitigating Risks Posed by the New Trump Administration Focus on Drug Cartels...

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Print Share by Email Share Back to top The Trump Administration’s crackdown on cartels and transnational criminal organizations (TCOs) operating abroad and in the United States is a significant Department of Justice (DOJ)...more

Troutman Pepper Locke

Recent SEC AML Enforcement Actions’ Impact on Compliance Efforts in the Cannabis Sector

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Investing in the cannabis industry is not without its risks, given the evolving regulatory landscape and the varying state and federal statuses of the product itself. The Financial Crimes Enforcement Network (FinCEN) has...more

Baker Donelson

DOJ Final Rule Casts Wider Net: Common Business Data May Now Trigger National Security Scrutiny

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If you thought your company's collection of email address, IP address, zip code, birth date, or cookie data was too mundane to catch the federal government's attention – think again. Effective April 8, 2025, a new DOJ final...more

Foley & Lardner LLP

Another FCA Cybersecurity Settlement Reinforces the Enforcement Trend

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A recent United States Department of Justice (DOJ) announcement highlights the fact that the government’s emphasis on cybersecurity enforcement under the False Claims Act (FCA) is not slowing down. According to the press...more

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