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Criminal Prosecution Economic Sanctions

The Volkov Law Group

Sanctions Enforcement on the Outer Edges of Trade Activity (Part II of II)

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We all know what a “core” sanctions violation looks like.  The heartland of such misconduct has been described on numerous occasions in OFAC enforcement actions and settlements.  In this environment, however, companies have...more

BCLP

Adoption of Directive (Ue) 2024/1226 on Criminalisation of Violations of EU Sanctions: What Are the Stakes Involved in Transposing...

BCLP on

On 19 May, Directive (EU) 2024/1226 on the definition of criminal offences and sanctions for breaches of EU restrictive measures, adopted by the EU Council on 24 April, entered into force. By harmonizing the laws of the...more

The Volkov Law Group

Life Sciences Company Escapes Criminal Charges for Employee’s Illegal Export Scheme

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Sigma-Aldrich, Inc., d/b/a MilliporeSigma (“MilliporeSigma”), a U.S. life sciences company based in Massachusetts, escaped criminal charges for export control violations, despite a former sales person’s scheme to illegally...more

Hogan Lovells

EU adopts directive criminalising sanctions violations

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On 24 April 2024, the European Union adopted a directive criminalizing the following sanctions violations:  The directive brings significant changes to EU sanctions enforcement by harmonising the rules on the violation of EU...more

BakerHostetler

Weekly Blockchain Blog - May 2024

BakerHostetler on

Fintech and Crypto Firms Announce New Cryptocurrency Products - According to recent reports, a major U.S. fintech firm will begin letting its users accept payments in USDC. ...more

Locke Lord LLP

OFAC, BIS and DOJ Issue TriSeal Guidance on Obligations of Non-U.S. Persons to Comply With U.S. Sanctions and Export Control Laws

Locke Lord LLP on

On March 5, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and the U.S. Department of Justice (“DOJ”) issued a...more

Holland & Knight LLP

New Tri-Seal Compliance Note Issued to Non-U.S. Persons

Holland & Knight LLP on

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), U.S. Department of Commerce's Bureau of Industry and Security (BIS) and U.S. Department of Justice (DOJ) on March 6, 2024, issued a Tri-Seal...more

The Volkov Law Group

The Coming Corporate Sanctions Enforcement Storm (Part I of II)

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There are some things you learn best in calm, and some in storm.  Willa Cather I know I sound like a broken record.  The Justice Department’s white collar criminal enforcement  has been trending down over the last few...more

Akin Gump Strauss Hauer & Feld LLP

New Executive Order Authorizes the Imposition of Secondary Sanctions on Foreign Financial Institutions Facilitating Russia’s...

Key Points - On December 22, 2023, President Biden issued E.O. 14114 “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities.” Specifically, E.O. 14114, which amends E.O. 14024 and E.O. 14068,...more

Ballard Spahr LLP

DOJ Appoints New Leaders of Corporate Enforcement Program

Ballard Spahr LLP on

Summary - The Department of Justice’s creation of two new leadership positions within the National Security Division (NSD) sends another strong signal to the private sector that federal law enforcement is pouring resources...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – July 2023 Update

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July saw two noteworthy Russia enforcement actions. A Russian national was arrested in Estonia and extradited to the United States after being charged with conspiring to procure U.S.-origin technologies and ammunition on...more

Oberheiden P.C.

The Most Important Thing to Keep in Mind When Looking for an OFAC Sanctions Lawyer

Oberheiden P.C. on

Company executives and stakeholders in charge of making decisions to insulate their business from legal liability by the Office of Foreign Assets Control (OFAC) at the U.S. Department of Treasury have a difficult choice to...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – June 2023 Update

Bass, Berry & Sims PLC on

You are reading the June 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. - June saw...more

The Volkov Law Group

Ransomware Criminal Prosecution of Russian National Underscores Pervasive Ransomware Risks

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In today’s world of cyber threats, many companies have fallen victim to ransomware attacks.  Corporate boards and senior executives face serious issues when their companies are attacked. The payment of ransom is not only...more

Dorsey & Whitney LLP

DOJ Strike Force Allegations Highlight Diversion and Theft from U.S. Companies

Dorsey & Whitney LLP on

The U.S. Department of Justice (“DOJ”) on May 16 announced criminal charges and arrests that highlight risks for companies from U.S. and non-U.S. networks and individuals that seek to unlawfully divert U.S. goods, services,...more

The Volkov Law Group

British American Tobacco Pays $629 Million to Settle Violations of North Korea Sanctions (Part I of II)

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The Justice Department warned  companies that sanctions enforcement is the “new FCPA.” DOJ just delivered its first salvo to back up its message....more

The Volkov Law Group

Supreme Court Authorizes Criminal Prosecution of Foreign State-Owned Entities

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The Supreme Court rejected a challenge by Halkbank, a Turkish state-owned bank, to its criminal prosecution for anti-money laundering violations and evasion of Iran Sanctions.  In a 7-2 decision, authored by Justice...more

Skadden, Arps, Slate, Meagher & Flom LLP

New US Efforts To Prosecute Sanctions Evasion and Export Control Violations May Require Compliance Programs To Be Updated

DOJ Increases Resources To Investigate and Prosecute Sanctions Evasion and Export Control Violations - On March 2, 2023, during a keynote speech at the American Bar Association’s annual White Collar Crime National...more

The Volkov Law Group

DOJ Flexes Enforcement Muscle to Target Viktor Vekselberg, a Russian Oligarch and Co-Conspirator Assisting in Evasion of Russia...

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I am sticking with my 2023 prediction – DOJ is committed to aggressive enforcement of the Russia sanctions.  Most of its efforts to date have been directed against Russian Oligarchs and significant evaders who are moving...more

The Volkov Law Group

Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating Russia Sanctions

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In an ironic twist (or you just can’t make this up moment, whichever you prefer), the Justice Department announced the arrest of Charles McGonigal, the former Special Agent in Charge (“SAC”) of the FBI’s Counterintelligence...more

WilmerHale

Sanctions, Fraud is Coming to Town: 2022 in Review

WilmerHale on

In 2022, the UK was forced to reckon with the charge of being soft on economic crime and being the destination of choice for kleptocrats seeking to launder their ill-gotten funds. No longer able to turn a blind eye to these...more

A&O Shearman

EU cracks down on the criminal enforcement of sanctions violations

A&O Shearman on

With a ninth sanctions package against Russia in the making, the EU’s sustained response to the war in Ukraine has demonstrated that sanctions will remain at the forefront of EU policymaking. The array of sanctions adopted...more

Paul Hastings LLP

[Webinar] Recent Trends in the U.S. Department of Justice’s International Criminal Investigations - September 8th, 9:00 am - 10:00...

Paul Hastings LLP on

Discussion with two former senior prosecutors on how to handle cases involving Japanese multinational corporations - It is not unusual for the U.S. Department of Justice to investigate non-U.S. multinational corporations...more

The Volkov Law Group

Department of Commerce’s Bureau of Industry and Security Charges Russian Oligarch Abramovich with Violating Russia Export Controls

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The Department of Commerce’s Bureau of Industry and Security (“BIS”) charged Russian oligarch Roman Abramovich with violating U.S. export controls by exporting U.S.-origin aircraft to Russia.  In a precedent setting action,...more

The Volkov Law Group

DOJ Charges Television Producer for Violating Crimea-Related Sanctions Program

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The U.S. Attorney’s Office for the Southern Direct of New York recently announced the indictment of Jack Hanick, a United States citizen, of violating the U.S. sanctions against Russia and false statements in connection with...more

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