News & Analysis as of

Sanction Violations Voluntary Disclosure Due Diligence

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

King & Spalding

New Ten-Year Statute of Limitations for Sanctions Violations

King & Spalding on

Implications Related to the Doubling of the Statute of Limitations for Civil and Criminal Violations of Two Primary Sanctions Authorities - SUMMARY - On April 24, 2024, President Biden signed into law a foreign military...more

Bass, Berry & Sims PLC

OFAC Dings U.S. Defense Contractor for Sanctions Violations, Inadequate Screening

Bass, Berry & Sims PLC on

• Penalties imposed for violations of U.S. sanctions on Russia and Ukraine • Violations identified during pre-acquisition due diligence on contractor • Denied persons screening was conducted but missed prohibited...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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