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Export Controls Due Diligence Economic Sanctions

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

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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)

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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

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

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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

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

Benesch

Pragmatic Regulatory Compliance for Global Risk

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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

Foley Hoag LLP

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

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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

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

Davis Wright Tremaine LLP

Protect Yourself: U.S. Exporters Advised To Obtain End-Use and End-User Statements for All Exports, Including EAR99 Items

According to a trade press report, a Bureau of Industry and Security ("BIS"), Department of Commerce official speaking at the March 2025 BIS Update Conference on Export Controls and Policy recommended that U.S. exporters...more

Cooley LLP

UK Government Publishes Guidance on Prevention of Russian Sanctions Evasion

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On 7 January 2025, the UK Office of Trade Sanctions Implementation (OTSI) published new guidance on how businesses should be preventing Russian sanctions evasion. This note provides a summary of this guidance to help you...more

American Conference Institute (ACI)

[Event] 9th Annual Canadian Forum on Global Economic Sanctions - February 26th - 27th, Toronto, ON, Canada

CI’s 9th Annual Canadian Forum on Global Economic Sanctions is designed to cover your top compliance challenges, offering unparalleled networking and benchmarking opportunities for economic sanctions, trade, financial crime,...more

K&L Gates LLP

Top Tips for Sanctions Compliance and Preventing Sanctions Evasion

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On 24 September 2024, the G7 released updated guidance on the prevention of evasion of export controls and sanctions imposed on Russia. The aim of the guidance is to “assist industry in identifying Russian evasion practices...more

Sheppard Mullin Richter & Hampton LLP

Banks Do Export, Too: New BIS Guidance Tags Financial Firms with Export Compliance Responsibilities

Pull quote: “Every export—every single one—has a related financial transaction” You are a banker. You do bankery things. You look at the ledgers, you tot up the numbers, you manage the accounts. Maybe you make loans,...more

American Conference Institute (ACI)

[Event] European Forum on Global Economic Sanctions - June 5th - 6th, Berlin, Germany

Hosted by the C5 Group Inc., the 2024 European Forum on Global Economic Sanctions will explore the evolution of the global economic sanctions landscape, analyzing everything from the shifting geopolitics around the globe, to...more

Morrison & Foerster LLP

OFAC Issues Omnibus Accounts Enforcement Case Involving Russia and Other Sanctions Programs

On March 14, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced its first enforcement case of the year and its first ever involving dealings with a Russian designated for sanctions...more

Mayer Brown

Russia: Investment Protection and Arbitration | Part 1

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Part 1: US warns of serious risks of continuing business in Russia: key options for foreign investors - In its recent business advisory, dated 23 February 2024, the United States (“US”) Government warns businesses and...more

Snell & Wilmer

United States Announces Largest Round of Sanctions Since the Start of Russia’s War in Ukraine

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The U.S. Government recently announced the largest round of sanctions against the Russian Federation (Russia) since the invasion of Ukraine two years ago. This multi-agency effort enacted over 500 sanctions against foreign...more

American Conference Institute (ACI)

Sanctions Compliance Measures to Mitigate Russia Trade Sanctions Evasion Tactics

The various and elusive tactics used by Russia to evade global sanctions and export controls have grown increasingly sophisticated over the last several months, putting the onus on multinational entities to become equally...more

Torres Trade Law, PLLC

Trade Due Diligence in the Context of an IPO

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Ensuring compliance with U.S. export controls, import regulations, and economic sanctions is common practice for companies that engage in international trade. These companies often have internal compliance policies and due...more

Seward & Kissel LLP

The Importance of Sanctions and Export Control Compliance

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The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more

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