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Voluntary Disclosure Office of Foreign Assets Control (OFAC) Today's Popular Updates

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

Troutman Pepper Locke

DOJ’s Criminal Division Announces Updates to White-Collar Enforcement and Corporate Policies

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On May 12, 2025, the Head of the Criminal Division (the Criminal Division or Division) at the Department of Justice (DOJ), Matthew R. Galeotti, issued key memoranda to Criminal Division personnel on the Division’s new...more

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

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On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

Adams & Reese

International Compliance Digest – August 2024

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August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more

Benesch

New Statute of Limitations Impacts M&A and International Trade Compliance

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New developments in international trade laws will have tangible and far-reaching impacts on transactions as well as day-to-day business operations.  President Biden’s signing of HR 815 means that once time-barred historic...more

Snell & Wilmer

The Uncertain World: Nearshoring, Economic Development, and the Next Frontier

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Historically, international trade regulation has swung between economic protectionism and national security concerns. Between World War II and the 2018 presidential election, the primary international trade regulatory issue...more

Bracewell LLP

“Export Controls Are the New Sanctions” and Other Enforcement Trends for 2024

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2023 was a banner year in the sanctions space and regulators seem primed to continue that performance in 2024. In December 2023, numerous government officials and industry experts convened at the New York Forum on Economic...more

The Volkov Law Group

Nasdaq Settles Iran Sanctions Violations for Pennies on the Dollar, Thanks to Voluntary Disclosure

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When it comes to OFAC sanctions violations, honesty is the best policy. Promptly and voluntarily disclosing violations upon their discovery can pay serious dividends. ...more

K2 Integrity

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Consolidating Information Regarding Voluntary Self-Disclosure Policies

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The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...more

Akin Gump Strauss Hauer & Feld LLP

Tri-Seal Compliance Note: Voluntary Self-Disclosure of Potential Violations

On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more

Foley Hoag LLP

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Regarding Self-Disclosure of Potential Sanctions Violations

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On July 26, 2023, the U.S. Department of Justice’s (“DOJ”) National Security Division (“NSD”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), and the U.S. Department of the Treasury’s Office of...more

Hogan Lovells

U.S. agencies signal reinforced export enforcement collaboration and partnership

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The U.S. Departments of Commerce, Justice and Treasury have issued a “Tri-Seal” Compliance Note regarding national security laws and regulations and the voluntary self-disclosure of potential violations, highlighting...more

Kelley Drye & Warren LLP

Federal Agencies Publish Tri-Seal Official Guidance on Voluntary Self-Disclosure of Violations

On July 26, 2023, the U.S. Department of Justice (“DOJ”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), and the U.S. Department of Treasury’s Office of Foreign Asset Control (“OFAC”) released a...more

Williams Mullen

Justice Department Adopts Significant Revisions to Voluntary Disclosure Program for Criminal Export Violations

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On December 13, 2019 the Department of Justice (“DOJ”) announced a major revision of its voluntary disclosure program for criminal violations of U.S. export and sanctions laws.  Under the new policy (the “Policy”), if a...more

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