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Corporate Enforcement Actions for Kingpin Act Violations Highlight Cartel-Related Enforcement Risks

Since the February 20, 2025 designations of eight cartels and transnational criminal organizations (TCOs) as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs), many have discussed the...more

BIS Implements “Affiliates Rule” (a 50% Rule) Applicable to Entity List and Military End User List

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an interim final rule (the “Affiliates Rule”), effective September 29, 2025, automatically imposing corresponding restrictions on entities 50%...more

Customs and Tariff Fraud Enforcement Intensifies: DOJ Wields Mix of Tools to Target Trade Violations

As the Trump Administration’s America First trade policy and reciprocal trade agreements continue to take shape, the DOJ is gearing up for increased criminal and civil enforcement of customs and tariff violations. In the...more

DOJ Using Broad Civil Forfeiture Authority After Designating Cartels as Foreign Terrorist Organizations

On September 3, 2025, the US Department of Justice (DOJ) announced that it had seized 300,000 kilograms of precursor chemicals used to produce methamphetamine that had been shipped from China and were intended for clandestine...more

DOJ Declines to Prosecute Private Equity Firm after Post-Acquisition Voluntary Self-Disclosure of Sanctions and Export Control...

In its first application of the policy on voluntary self-disclosures (“VSDs”) in connection with mergers and acquisitions (“M&A”), on June 16, 2025, the US Department of Justice’s (“DOJ”) National Security Division (“NSD”)...more

DOJ Already Filing Material Support Charges After Designating Cartels as Foreign Terrorist Organizations

On February 20, 2025, the United States designated eight cartels and transnational criminal organizations (TCOs) as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). Since then, the US...more

Ten Takeaways from the DOJ Criminal Division’s New Playbook on White Collar Enforcement Priorities

On May 12, 2025, the U.S. Department of Justice ("the DOJ" or "the Department") unveiled its new playbook for prosecuting white-collar and corporate crime. DOJ announced enforcement priorities for the Criminal Division ("the...more

DOJ Issues Guidance on Bulk Sensitive Data Rules

On April 11, 2025, the Department of Justice (DOJ) issued guidance (Guidance) to assist individuals and entities in coming into compliance with its final rule, referred to as the "Data Security Program" (DSP Rule), which...more

DOJ Issues Final Rule Prohibiting and Restricting Transfers of Bulk Sensitive Personal Data

The Department of Justice (DOJ) issued a final rule (the "Rule") on December 27, 2024, implementing Executive Order 14117 "Preventing Access to Americans' Bulk Sensitive Personal Data and United States Government-Related Data...more

United States Designates Eight Cartels and Transnational Criminal Organizations

Effective February 20, 2025, the United States Designated Eight Cartels and Transnational Criminal Organizations (TCOs) as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs)....more

DOJ Implements Major Changes to National Security Priorities

On February 5, 2025, President Trump's nominee to lead the Justice Department (the "Department"), Pamela Bondi, was confirmed by the Senate to serve as the U.S. Attorney General. Bondi immediately took action to reshape the...more

FCPA Freeze and Refocus: Is Enforcement Becoming a Tool to Promote U.S. Economic, Foreign Policy and National Security Interests?

On February 10, 2025, President Trump signed an executive order instructing the Attorney General of the United States to pause enforcement of the Foreign Corrupt Practices Act ("FCPA") and to issue updated guidelines for...more

DOJ Recommends AI-Specific Sentencing Enhancement

In early 2024, we published alerts on separate sets of remarks from Department of Justice ("DOJ") Deputy Attorney General Lisa Monaco warning that the DOJ would be seeking stiffer sentences for offenses made significantly...more

The Shadow Financial System

The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

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