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DOJ Announces Shift Toward Corporate Enforcement for Sanctions and Export Control Violations

Deputy Attorney General (DAG) Lisa Monaco once again delivered groundbreaking remarks at the American Bar Association (ABA) National Institute on White Collar Crime (ABA White Collar Conference) on March 2, 2023, this time...more

OFAC Takes Action Against Virtual Currency Tornado Cash in Novel Application of Sanctions Authorities

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), on August 8, 2022, sanctioned virtual currency mixer Tornado Cash. OFAC alleged that it had been “used to launder more than $7 billion worth of...more

DOJ’s Civil Cyber-Fraud Initiative Highlights False Claims Act Cybersecurity Risks for Government Contractors

On October 6, 2021, the U.S. Department of Justice (DOJ) announced an initiative to pursue civil False Claims Act (FCA) enforcement actions against government contractors that knowingly fail to follow required cybersecurity...more

OFAC Issues Second Ransomware Advisory and Designates Virtual Currency Exchange for Sanctions

Agency’s Focus on Cryptocurrency and Blockchain Continues - On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released an updated advisory to “highlight the sanctions...more

DOJ’s False Claims Act Recoveries Drop to $2.2 Billion in FY 2020—But the Decrease May be Short-Lived

The U.S. Department of Justice (DOJ) recovered more than $2.2 billion in settlements and judgments from civil cases under the False Claims Act (FCA) in the fiscal year ending September 30, 2020. This is a drop of more than...more

OFAC Issues Sanctions Compliance Program Guidance

The Office of Foreign Assets Control (OFAC), an agency of the U.S. Department of the Treasury, administers and enforces U.S. economic sanctions programs against targeted foreign governments, individuals, groups and entities...more

OFAC Warns that Venezuela’s Proposed Digital Currency May Violate U.S. Sanctions

On January 19, 2018, the U.S. Office of Foreign Assets Control (OFAC), in response to a question, warned that a U.S. person’s acquisition of, or dealing in, a cryptocurrency that Venezuela intends to issue in the future may...more

Court Opinion on Liability for Re-Exports to Iran Spurs Practical Guidance for U.S. Exporters

A recent federal appeals court decision addresses a familiar issue for many companies: When can a U.S. exporter be liable for a product that is re-exported to a sanctioned country, such as Iran? This update summarizes the...more

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