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Foreign Policy Enforcement Actions Compliance

K&L Gates LLP

What You Need to Know About the United Kingdom Issuing Sanctions Guidance for Non-UK Businesses

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The United Kingdom’s Foreign, Commonwealth and Development Office has published guidance on United Kingdom’s Russia sanctions compliance for non-UK businesses operating outside the United Kingdom (the Guidance). It also...more

Wiley Rein LLP

Sens. Grassley and Peters Introduce Foreign Agents Transparency Act to Enable DOJ to Require Retroactive FARA Registration

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On March 13, 2024, Senator Chuck Grassley (R-IA), Chairman of the Senate Judiciary Committee, and Senator Gary Peters (D-MI), Ranking Member of the Homeland Security and Governmental Affairs Committee, introduced the Foreign...more

Wiley Rein LLP

Congress’ Continued Focus on the Administration and Enforcement of FARA in the 119th Congress

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On March 6, 2025, Senator Chuck Grassley (R-IA), Chairman of the Senate Judiciary Committee, and Senator Gary Peters (D-MI), Ranking Member of the Homeland Security and Governmental Affairs Committee, reintroduced the...more

Vinson & Elkins LLP

Future of FCPA Enforcement Uncertain (For Now) as New Administration Revamps the Law Enforcement Toolkit

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Among the drumbeats of rapid pronouncements and policy shifts since January 20, 2025, the Trump Administration recently issued a 180-day pause on new investigations and enforcement actions involving the U.S. Foreign Corrupt...more

Proskauer Rose LLP

Back to the Future: Protection of Foreign Affairs Focus for FCPA Enforcement

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Under the guise of protecting the President’s authority to conduct foreign affairs, on February 10, 2025, President Donald J. Trump signed an Executive Order pausing enforcement of the U.S. Foreign Corrupt Practices Act...more

Hogan Lovells

Criminal FCPA enforcement paused. Now what?

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On February 10, 2025, President Trump ordered the U.S. Department of Justice (DOJ) to pause enforcement of the Foreign Corrupt Practices Act (FCPA) and issue new enforcement guidelines that take into consideration U.S....more

Snell & Wilmer

FARA's Pendulum: Shifts in Foreign Agent Regulation

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On her first day in office, Attorney General Pamela Bondi issued a memorandum signaling a significant shift in the Department of Justice’s (DOJ) approach to Foreign Agents Registration Act (FARA) enforcement. The memorandum...more

The Volkov Law Group

Haas Automation Fined $2.5 Million for Export Control and Sanctions Violations Involving China and Russia

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In one of the first enforcement actions of 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order against Haas Automation, Inc., a leading manufacturer of computer numerical...more

American Conference Institute (ACI)

[Webinar] Virtual Passport to Proficiency in Economic Sanctions - March 4th - 27th, 1:30 pm - 4:30 pm EST

ACI’s virtual Passport to Proficiency Economic Sanctions features 21 hours of in-depth training led by a distinguished faculty of sanctions experts, drawn from diverse industries, the virtual event will provide in-depth...more

K&L Gates LLP

Article 8a "Best Efforts" Explained

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On 24 June 2024, the European Union (EU) implemented its 14th package of sanctions against Russia to combat its continued aggression against Ukraine. The package introduced new anti-circumvention measures to strengthen...more

Morgan Lewis

DOJ’s Latest Attempt at Modernizing FARA Signals Greater Focus on Compliance and Enforcement

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Following a decade of increased enforcement of what has been considered an oft-confusing law, the Department of Justice recently published a Notice of Proposed Rulemaking proposing several changes to regulations implemented...more

The Volkov Law Group

American Life Insurance Company Settles with OFAC for $178,421 Related to Apparent Violations of Iranian Transactions and...

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently settled with American Life Insurance Company (“ALICO”), a Delaware-based subsidiary of MetLife, Inc., for $178,421, addressing apparent...more

The Volkov Law Group

OFAC Imposes $860,000 Penalty on Vietnamese Beverage Company for Violations of North Korean Sanctions

The Volkov Law Group on

North Korea Sanctions Violations - In a recent enforcement action, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed an $860,000 penalty on Vietnam Beverage Company Limited (“VBCL”), a...more

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

K2 Integrity on

On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

The Volkov Law Group

Preparing for the Storm — Effective Compliance in the New Sanctions Era (Part II of II)

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If companies operated with perfect governance mechanisms and controls, they would all be ready for the coming sanctions enforcement storm.  However, that is not the corporate reality.  Even after several companies are the...more

The Volkov Law Group

BIS Imposes $153,175 Penalty Against Wabtec Corporation to Resolve Multiple Violations of Antiboycott Regulations

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Wabtec Corporation (“Wabtec”)—a global manufacturer and supplier of rail technology headquartered in Pittsburgh, Pennsylvania—recently settled an administrative enforcement proceeding with the U.S. Department of Commerce’s...more

The Volkov Law Group

U.S. Government Charges Parties with Violating U.S. Sanctions and Export Control Laws

The Volkov Law Group on

As we have repeatedly noted in the context of other blog posts and webinars in which various representatives of The Volkov Law Group have participated, the violation of existing U.S. sanctions and export control regulations...more

The Volkov Law Group

3M Pays OFAC $9.6 Million to Resolve Egregious Iran Sanctions Violations

The Volkov Law Group on

The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned healthcare...more

The Volkov Law Group

BIS Signals New Enforcement Initiative for Antiboycott Compliance — Pratt and Whitney Settles Antiboycott Violations

The Volkov Law Group on

On September 27, 2023, the United States Department of Commerce’s Office of Antiboycott Compliance, a division of the Bureau of Industry and Security (“BIS”), publicized an unanticipated and relatively rare enforcement action...more

The Volkov Law Group

DOJ Resolves First Corporate Sanctions Case Involving Iran Sanctions Program

The Volkov Law Group on

The Justice Department has touted the upcoming wave of corporate prosecutions for criminal sanctions violation as the era of “The New FCPA.” DOJ’s reference is intended to communicate a strong message – companies are going to...more

Oberheiden P.C.

OFAC Compliance: Avoiding Common Root Causes of Compliance Policy Breakdowns and Deficiencies

Oberheiden P.C. on

For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more

The Volkov Law Group

OFAC Settles with Construction Specialties, Inc. for $660,594 for Violations of Iran Sanctions

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Construction Specialties, Inc. (“CSI”), a U.S. company specializing in the sale of building materials, agreed to pay $660,594 to settle its liability for three violations of OFAC’s sanctions on Iran. CSI’s illegal conduct...more

The Volkov Law Group

Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating Russia Sanctions

The Volkov Law Group on

In an ironic twist (or you just can’t make this up moment, whichever you prefer), the Justice Department announced the arrest of Charles McGonigal, the former Special Agent in Charge (“SAC”) of the FBI’s Counterintelligence...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Informed Board - Fall 2022

The proliferation of U.S. sanctions and other regulations affecting cross-border transactions has implications for directors, who may be personally liable for violations in some cases. Meanwhile, the Securities and Exchange...more

The Volkov Law Group

DC Circuit Court Rejects Federal Express Challenge to Civil Liability for Violations of Export Regulations

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The D.C Circuit Court of Appeals sits in a unique position as the primary reviewing court for federal government agency actions.  As a result, the D.C. Circuit sits in a high-profile position and several judges have...more

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