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Disruptive Technology Strike Force Announces Its First Declination to Prosecute Under the National Security Division’s Voluntary...

On May 22, 2024, the Department of Justice’s National Security Division (“NSD”) announced its first declination of prosecution for a company under the voluntary self-disclosure program established by the National Security...more

Disruptive Technology Strike Force Continues Focus on Trade Secret Theft, Export Control Enforcement

The Disruptive Technology Strike Force hosted a summit on Feb. 7-8, 2024, in Phoenix, Arizona, to commemorate its one-year anniversary. The Strike Force is an interagency law enforcement effort aimed at preventing...more

Departments of Justice, Commerce and Treasury Issue Tri-Seal Compliance Note on Voluntary Self-Disclosure of Potential Violations

On July 26, 2023, the U.S. Department of Justice’s National Security Division, U.S. Department of Commerce’s Bureau of Industry and Security, and U.S. Department of the Treasury’s Office of Foreign Assets Control issued a...more

Disruptive Technology Strike Force Initiates Federal Prosecutions Targeting Trade Secret Theft

In early 2023, the U.S. Department of Justice and U.S. Department of Commerce launched the Disruptive Technology Strike Force to target illicit actors, strengthen supply chains and protect critical technology assets from...more

U.S. Department of Justice and Partners Increasing Enforcement of Sanctions and Export Controls

It has been a little more than a year since Russia’s invasion of Ukraine, and the war continues to rage. In an effort to deter the Russian government and weaken its military capabilities, the United States has imposed...more

Less is More? DOJ Signals Shift to More Targeted Evidence Collection

For a corporation receiving a grand jury subpoena, the most difficult (and expensive) part of a U.S. Department of Justice (DOJ) inquiry is often sifting through corporate data to find relevant material. That is proving to be...more

DOJ Launches “Task Force KleptoCapture” in Response to Russian Invasion

Last week, the U.S. Department of Justice (DOJ) announced the launch of an aggressive interagency law enforcement task force, Task Force KleptoCapture. The Task Force represents another U.S. enforcement initiative in response...more

The Perils of Pleading the Fifth in the Corporate Fraud Context

“Pleading the Fifth” is one of the most commonly known phrases in our legal system, and the right against self-incrimination is one of the Constitution’s most meaningful protections. That said, in the corporate fraud context,...more

Second Circuit Clarifies Limits of FCPA’s Extraterritorial Reach

The U.S. Court of Appeals for the Second Circuit narrowed the reach of the Foreign Corrupt Practices Act (“FCPA” or “the Act”) in ruling that the government cannot use aiding and abetting or conspiracy statutes to charge a...more

The Export/Immigration Dilemma: Don’t Let OSC Catch Your HR Department Unawares

On March 31, 2016, the U.S. Department of Justice’s Office of Special Counsel for Immigration-Related Unfair Employment Practices (OSC) issued a carefully worded technical assistance letter addressing the complex interplay...more

A New FCPA Policy May Be Coming, but Questions Remain

Just a week after the U.S. Department of Justice (DOJ) introduced its new Compliance Counsel, and just a month after the DOJ issued the “Yates memo,” it is now being reported that the DOJ is considering a new policy that...more

Casino Forfeiture a Reminder that FinCEN’s Regulatory Oversight May Involve DOJ and Criminal Penalty

The civil money penalty was surprising for two reasons: first, that FinCEN would investigate and fine a casino unfamiliar even to analysts who cover the gaming industry, on an island chain few knew existed; and second, for...more

White House Hostage Policy Leaves Risk on Table for Third Parties

Last month, the White House announced a change in its policy toward overseas hostage-takings of U.S. citizens. The new policy, accompanied by an Executive Order, aims to effect policy changes at home and overseas, including a...more

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