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Private Equity Economic Sanctions Mergers

Bass, Berry & Sims PLC

Sanctions Enforcement Update: DOJ Declines Prosecution After Post-Acquisition Disclosure

In June 2025, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) announced that Unicat Catalyst Technologies, LLC (Unicat), a Texas-based petrochemical company, had agreed to settle its potential civil liability...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

White & Case LLP

DOJ Declines to Prosecute Private Equity Firm after Post-Acquisition Voluntary Self-Disclosure of Sanctions and Export Control...

White & Case LLP on

In its first application of the policy on voluntary self-disclosures (“VSDs”) in connection with mergers and acquisitions (“M&A”), on June 16, 2025, the US Department of Justice’s (“DOJ”) National Security Division (“NSD”)...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

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

StoneTurn

The Next Chapter in Sanctions Due Diligence

StoneTurn on

In today’s rapidly changing sanctions landscape, a bare minimum approach to sanctions compliance can leave organizations open to a range of risks that can wreak havoc across their business. Holistic approaches to due...more

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