National Security, Non-Prosecution Agreements, Office of Foreign Assets Control (OFAC)

DOJ Declination of Private Equity Firm Underscores Need for Robust M&A Due Diligence

Proskauer Rose LLP on 6/30/2025

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

DOJ Announces First-Ever Corporate Declination Under National Security Division’s Voluntary Self-Disclosure Program

Akin Gump Strauss Hauer & Feld LLP on 6/7/2024

Key Points - On May 21, 2024, the DOJ announced its first ever declination under the NSD’s updated Enforcement Policy, declining to prosecute Sigma-Aldrich Inc., d/b/a MilliporeSigma (a subsidiary of Merck KGaA, Darmstadt,...more

Federal Agencies Highlight Benefits of Self-Disclosure, Emphasize Enforcement of Trade Violations in Tri-Seal Compliance Note

Jones Day on 8/22/2023

In a coordinated announcement, federal agencies stress the benefits of voluntarily disclosing potential trade violations while emphasizing increased enforcement....more

Honesty is Good for Your Bottom Line: Commerce, Treasury, and DOJ Tout the Benefits of Voluntary Self Disclosure in Tri-Seal...

Venable LLP on 8/2/2023

Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more

DOJ Announces Renewed Focus on Export Control and Sanctions Enforcement

Morrison & Foerster LLP on 10/15/2021

In a keynote address at the Global Investigations Review Connect: New York conference on October 5, Principal Associate Deputy Attorney General John Carlin provided insights into future Department of Justice (“DOJ” or the...more

SAP Reaches Broad Settlement and Agrees to Pay More Than $8 Million for Violations of Iran Sanctions Program (Part I of IV)

The Volkov Law Group on 5/3/2021

In a precedent-setting agreement, the Justice Department, OFAC and the Bureau of Industry and Security announced a settlement with SAP SE for more than $8 million for numerous violations of the Iran Sanctions program....more

White Collar Crime Law Enforcement in a Trump Justice Department - 8 Predictions

Cadwalader, Wickersham & Taft LLP on 11/30/2016

After a conventional presidential campaign, determining the policy priorities and direction of the incoming administration with respect to the Justice Department’s white collar law enforcement responsibilities can be a...more

National Security › Non-Prosecution Agreements › Office of Foreign Assets Control (OFAC)