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Export Controls Compliance White Collar Crimes

Venable LLP

Defense Contractor Resolves DOJ and SEC FCPA, FCA, Export Controls Violations for $950 Million

Venable LLP on

In October 2024, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) announced settlements with Raytheon Company, a division of multinational defense contractor RTX, over defective pricing and...more

The Volkov Law Group

The Sanctions Year in Review: DOJ takes First Steps to Enforce “The New FCPA” While OFAC’s Enforcement Actions Decline

The Volkov Law Group on

Enforcement and compliance prognosticators (like myself) continued to push DOJ’s promise to transform sanctions enforcement into the era of “the new FCPA.” While DOJ’s promise to bring about an aggressive corporate...more

The Volkov Law Group

Commerce Department Updated its Voluntary Self-Disclosure Policy for Export Controls Violations

The Volkov Law Group on

The Commerce Department’s Bureau of Industry and Security (“DOC-BIS”) is adopting procedures to generate voluntary self-disclosures for violations of export controls laws.  Companies have to weigh carefully the risks when...more

Foley Hoag LLP - White Collar Law &...

Enforcement of U.S. Trade Sanctions and Export Controls in 2023 and What to Expect In 2024

This is the tenth in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. Our previous post, "Health Care Fraud Enforcement in 2024," can be found here....more

The Volkov Law Group

DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations

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As DOJ, OFAC and BIS ramp up sanctions and export controls enforcement, they have continued to provide important compliance guidance.  You have to give the enforcement agencies credit — on the one hand, they regularly warn of...more

American Conference Institute (ACI)

Sanctions Compliance Measures to Mitigate Russia Trade Sanctions Evasion Tactics

The various and elusive tactics used by Russia to evade global sanctions and export controls have grown increasingly sophisticated over the last several months, putting the onus on multinational entities to become equally...more

The Volkov Law Group

BIS Announces Further Enhancements to Voluntary Self-Disclosure Process

The Volkov Law Group on

On January 16, 2024, the U.S Department of Commerce’s Bureau of Industry and Security (“BIS”) released a series of enhancements to its existing voluntary self disclosure (“VSD”) program, pursuant to which organizations...more

American Conference Institute (ACI)

Navigating U.S. Sanctions and Export Control Restrictions

Over the last several months, companies have become entangled in an increasingly complex web of new and expanded sanctions and export control restrictions related to Russia in response to its war on Ukraine. The current...more

The Volkov Law Group

Justice, Commerce and Treasury Departments Issue Comprehensive Tri-Party Voluntary Disclosure Guidelines for Sanctions and Export...

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In another significant step notifying global businesses of the new realities – companies are about to face aggressive coordinated criminal and civil prosecutions for sanctions and export control violations.  The last piece in...more

The Volkov Law Group

A Five Step Program for Every Company to Address the New Enforcement Threats

The Volkov Law Group on

Companies have to demand a new focus from their CEOs, senior executives and legal compliance team in response to the new DOJ and regulatory initiatives.  These steps are not just suggestions nor items that can be prioritized...more

The Volkov Law Group

Corporate Governance Challenges in an Evolving Risk Era

The Volkov Law Group on

We are living in a rapidly changing economic landscape. Companies are under the gun to navigate “traditional issues,” such as challenging economic conditions ranging from inflation, and a predicted recession, to supply chain...more

Sheppard Mullin Richter & Hampton LLP

“Sanctions Are The New FCPA”: DOJ Increases Focus on Sanctions and Export Control Enforcement

On March 2, 2023, Deputy Attorney General Lisa Monaco delivered remarks to the ABA’s National Institute on White Collar Crime. Unsurprisingly, her remarks focused heavily on inspiring a culture of compliance – including...more

The Volkov Law Group

DOJ Outlines Aggressive White Collar Enforcement Measures and New Compliance Expectations (Part I of II)

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The Justice Department continues to push on white collar corporate enforcement, and the intersection of national security sanctions and export controls with corporate criminal enforcement.  Last week, Lisa Monaco, DOJ’s...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Focuses on Corporate Crime Involving Sanctions Evasion, Export Controls Violations and Similar Economic Crimes

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

Dorsey & Whitney LLP

Department of Justice Announces First-Ever Pilot Program on Compensation Incentives and Clawbacks, Revisions to Corporate Guidance...

Dorsey & Whitney LLP on

On March 2, 2023, in remarks delivered at the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced a new policy creating incentives for companies to adopt...more

The Volkov Law Group

Commerce Department Tacks to New Aggressive Enforcement Program

The Volkov Law Group on

The Commerce Department’s Bureau of Industry and Security (“BIS”) has decided to join the enforcement club.  BIS’s recent announcement of new policies to administrative actions should not be surprising.  ...more

The Volkov Law Group

Sanctions Enforcement: “The New FCPA”

The Volkov Law Group on

Hold onto your hats – while we are on the cusp of more FCPA enforcement actions, the Justice Department and OFAC are gearing up for real and significant sanctions enforcement actions.  The dye is cast, so here we go. ...more

The Volkov Law Group

Nordgas Settles with OFAC As Part of UniControls Violations of Iran Sanctions Program

The Volkov Law Group on

The Treasury Department’s Office of Foreign Asset Control (OFAC)continues to pile up sanctions enforcement actions.  As the Biden Administration slowly takes over the reins of the Department of Treasury, OFAC enforcement is...more

The Volkov Law Group

OFAC On A Roll: Whitford Worldwide Company Agrees to Pay $824k for Violations of Iran Sanctions

The Volkov Law Group on

When you are hot, you are hot.  (And when you are not, you are not; Thank you Jerry Reed, Country Singer).  OFAC is hot and resumed its enforcement streak, settling three enforcement actions in three weeks....more

The Volkov Law Group

DOJ Announces Voluntary Disclosure Program for Criminal Export and Sanctions Violations

The Volkov Law Group on

The Justice Department is often criticized for its lack of transparency.  But when it comes to policy changes or initiatives, DOJ is more than transparent – DOJ always tells the public what it plans to do and then does it....more

Foley Hoag LLP - White Collar Law &...

White Collar Year in Preview: Sanctions/Export Controls Trends in 2020

This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - June 2019

ANTICORRUPTION DEVELOPMENTS - Deputy Assistant Attorney General Matt Miner Delivers Remarks at the American Bar Association, Criminal Justice Section Third Global White Collar Crime Institute Conference - On June 27,...more

The Volkov Law Group

FLIR Systems Pays $15 Million Civil Penalty for AECA and ITAR Violations and Earns First DTCC Monitor (Part I of II)

The Volkov Law Group on

In an extraordinary enforcement action, the US Department of State reached a comprehensive settlement with FLIR Systems, Inc. (FLIR) to resolve violations of the Arms Export Control Act and the International Traffic in Arms...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - June 2017

ANTICORRUPTION DEVELOPMENTS - Linde Group Receives DOJ Declination Pursuant to FCPA Pilot Program - On June 16, 2017, German based chemical and gas company Linde Group’s American affiliates, Linde North America Inc....more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS – Former Magyar Telekom Executives Settle Bribery Charges – On April 24, 2017, the Securities and Exchange Commission (SEC) announced that two former executives of Magyar Telekom, a...more

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