Key Points - On May 21, 2024, the DOJ announced its first ever declination under the NSD’s updated Enforcement Policy, declining to prosecute Sigma-Aldrich Inc., d/b/a MilliporeSigma (a subsidiary of Merck KGaA, Darmstadt,...more
6/7/2024
/ Bureau of Industry and Security (BIS) ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Enforcement ,
Export Controls ,
Incentives ,
National Security ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes
Executive Summary -
- On March 7, 2024, the NSD of the DOJ issued an updated NSD Enforcement Policy to include a new section covering VSDs in connection with mergers and acquisitions.
- These updates follow repeated...more
3/19/2024
/ Acquisitions ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
Mergers ,
National Security ,
Policies and Procedures ,
Regulatory Reform ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers
Key Points -
On January 16, 2024, Matthew Axelrod, Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s BIS announced key updates to BIS’s VSD process. The updates are also now reflected on BIS’s...more
1/26/2024
/ Bureau of Industry and Security (BIS) ,
Enforcement ,
Export Administration Regulations (EAR) ,
Exports ,
National Security ,
Negligence ,
Non-Prosecution Agreements ,
Penalties ,
Penalty Reductions ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
Voluntary Disclosure
Key Points -
On March 2, 2023, DOJ announced that its NSD would hire more than 25 new prosecutors to investigate and prosecute sanctions evasion, export controls violations and similar economic crimes. Consistent with...more
Key Points -
The U.S. Department of Commerce has reorganized and clarified the regulations describing when foreign-produced items outside the United States are and are not subject to the licensing and other obligations of...more