News & Analysis as of

Sanction Violations Mergers

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

Bracewell LLP

DOJ Spotlights Voluntary Self Disclosure in M&A as it Adapts to New National Security Threats

Bracewell LLP on

The past few months have seen numerous high-profile enforcement actions highlighting an increasing trend, what Deputy Attorney General Lisa Monaco called “the biggest shift in corporate criminal enforcement that I’ve seen...more

NAVEX

The Subtle but Significant Shift at U.S. Justice Department

NAVEX on

In October, deputy attorney general Lisa Monaco made headlines when she announced a new leniency policy at the U.S. Justice Department for companies that disclose compliance violations discovered during mergers and...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - June 2022 - The Importance of Compliance Strength During Rapid Growth What are your...

Rapid growth, which usually indicates a positive stage for companies, comes with potential downsides, as seen in the cautionary tale of Toll Holdings. Background- The Office of Foreign Asset Controls (OFAC) fined Toll...more

Bass, Berry & Sims PLC

US Hammers ZTE with Export Denial Order, May Further Weaken Trade with China

Bass, Berry & Sims PLC on

• 7-year denial order imposed against Chinese telecommunications equipment maker • Denial order strictly limits business with company • Action comes as U.S. imposes other trade restrictions on China On April 16, U.S....more

Bass, Berry & Sims PLC

U.S. Dental Supply Company Penalized for Violating Iran Sanctions

Bass, Berry & Sims PLC on

•Many medical products can be exported to Iran – so long as a license is obtained •Imposition of successor liability underscores importance of pre-transaction due diligence •OFAC enforcement, as in the past, continues...more

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