The first-ever tri-seal Note highlights tactics used to circumvent Russia-related restrictions, while NSD adds 25 prosecutors focusing on sanctions and export controls.

In May 2022, shortly after hostilities in Ukraine began, Deputy Attorney General Lisa Monaco first announced, “Sanctions are the new [Foreign Corrupt Practices Act] FCPA.” Over the past several weeks, the Department of Justice has issued a series of announcements that provide additional context on what that pronouncement will mean in practice.