On September 11, 2023, the Justice Department’s National Security Division (the “Division”) announced that it had made key appointments to lead the Division’s Corporate Enforcement program.  The new appointees include Ian Richardson as the first Chief Counsel for Corporate Enforcement and Christian Nauvel as Deputy Chief Counsel for Corporate Enforcement.  Richardson and Nauvel will be tasked with overseeing the Division’s investigation and prosecution of corporate crime deemed to relate to U.S. national security.  The Division had previously announced the establishment of these positions in March 2023, when Deputy Attorney General Lisa Monaco also announced that the Division would add more than 25 prosecutors to investigate and prosecute sanctions evasion, export control violations and other such economic crimes.

The appointments come as the Justice Department—and the United States government more generally—is increasingly focused on the national security implications of cross-border business dealings.  Speaking about the appointments of Richardson and Nauvel, Assistant Attorney General Matthew Olsen explained that “[i]n an era of renewed nation-state competition, corporations are on the front lines of the fight to defend [the United States’] national security” and that the Justice Department has “watched with concern as investigations of corporate misconduct increasingly reveal violations of laws that protect the United States.”

This growing focus on the intersection of national security and international business is also reflected in Richardson’s and Nauvel’s resumes.  Richardson previously served as an Assistant U.S. Attorney for the Eastern District of New York, where he obtained the Justice Department’s first-ever corporate conviction for providing material support to foreign terrorist organizations.  Nauvel previously served as Senior Counsel to the Assistant Attorney General for the Justice Department’s Criminal Division, and he served as a lead prosecutor in U.S. v. Huawei, in which the Justice Department charged Chinese telecoms company Huawei with alleged racketeering, sanctions violations and trade secret theft.

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