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Enforcement Actions Office of Foreign Assets Control (OFAC) Private Equity

Bass, Berry & Sims PLC

Sanctions Enforcement Update: DOJ Declines Prosecution After Post-Acquisition Disclosure

In June 2025, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) announced that Unicat Catalyst Technologies, LLC (Unicat), a Texas-based petrochemical company, had agreed to settle its potential civil liability...more

McDermott Will & Emery

From risk to relief: PE firm avoids prosecution with swift disclosure

In June 2025, the US Department of Justice (DOJ) announced that it declined to prosecute a private equity firm and its affiliates following the firm’s voluntary self-disclosure of criminal violations of US sanctions and...more

White & Case LLP

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

White & Case LLP on

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

Akin Gump Strauss Hauer & Feld LLP

Acquirors Beware: PE Firm Escapes DOJ Prosecution, but Acquired Entity Hit With $2 million+ in Penalties

In March 2024, NSD issued an updated Enforcement Policy for Business Organizations (NSD Enforcement Policy) that includes the M&A Policy.  Under the M&A Policy, where an acquiring company makes a qualifying voluntary...more

Foley & Lardner LLP

Private Equity and the New Trump Administration: Your Top Ten Questions Answered

Foley & Lardner LLP on

The election of President Trump contained some positive signs for Private Equity (PE) fund managers. These included potential lower corporate taxes, a ten-percent tax holiday for funds parked overseas, large infrastructure...more

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