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Private Equity Economic Sanctions Office of Foreign Assets Control (OFAC)

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

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

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

Lowenstein Sandler LLP

OFAC Imposes Largest-Ever Penalty on Nonbank Financial Institution for Egregious and Sustained Sanctions Violations—a $216M...

Lowenstein Sandler LLP on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a historic $215,988,868 civil monetary penalty against GVA Capital Ltd. (GVA), a venture-capital firm registered in the Cayman Islands...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

Hogan Lovells

OFAC, EU, and UK financial sanctions - are you compliant? Top tips for financial institutions, private equity, debt funds and...

Hogan Lovells on

On 6 November we held a breakfast seminar focusing on the most important sanctions issues affecting the City and how to manage compliance with different financial sanctions regimes effectively. ...more

Hogan Lovells

U.S. Sanctions regulator outlines expectations for Global Sanctions Compliance: impact on Private Equity

Hogan Lovells on

On 2 May 2019, the U.S. Treasury's Office of Foreign Assets Control ("OFAC"), the agency responsible for enforcing economic sanctions, published "A Framework for OFAC Compliance Commitments" (the "Framework") which outlines...more

Foley & Lardner LLP

Private Equity and the New Trump Administration: Your Top Ten Questions Answered

Foley & Lardner LLP on

The election of President Trump contained some positive signs for Private Equity (PE) fund managers. These included potential lower corporate taxes, a ten-percent tax holiday for funds parked overseas, large infrastructure...more

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