News & Analysis as of

Office of Foreign Assets Control (OFAC) Department of Justice (DOJ) Due Diligence

A&O Shearman

U.S. DOJ first declination for sanctions violation since creation of M&A safe harbor

A&O Shearman on

On June 16, 2024, the U.S. Department of Justice’s (DOJ) National Security Division (NSD) and the U.S. Attorney’s Office for the Southern District of Texas (SDTX) announced the first-ever declination to prosecute a firm and...more

A&O Shearman

DOJ Issues First-Ever Declination For Sanctions Violations Since Creation Of The M&A Safe Harbor Policy

A&O Shearman on

On June 16, 2024, the U.S. Department of Justice’s (“DOJ”) National Security Division (“NSD”) and the U.S. Attorney’s Office for the Southern District of Texas (“SDTX”) announced the first-ever declination to prosecute a firm...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

The Volkov Law Group

Lessons Learned from the Unicat Settlement (Part III of III)

The Volkov Law Group on

The Unicat settlement provides some important insights into the Trump Administration’s direction on trade enforcement. It underscores the importance of voluntary disclosure, cooperation and remediation, the tri-part...more

Proskauer Rose LLP

DOJ Declination of Private Equity Firm Underscores Need for Robust M&A Due Diligence

Proskauer Rose LLP on

On June 16, 2025, the U.S. Department of Justice (“DOJ”), including its National Security Division (“NSD”) and the U.S. Attorney’s Office for the Southern District of Texas, announced that they would not prosecute White Deer...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

American Conference Institute (ACI)

[Event] Trade & Sanctions Compliance for the Oil and Gas Industry - May 21st - 22nd, Houston, TX

Between tariffs, tightening export controls, evolving sanctions, and ramped up enforcement, the cost and complexity of compliance is rising for oil and gas supply chains. ACI’s Trade & Sanctions Compliance for the Oil and...more

Bracewell LLP

Guiding Your Company Through Trump’s New Latin America Enforcement Policy

Bracewell LLP on

Shortly after President Trump’s second inauguration, his executive branch took steps to further one of his signature promises: securing the southern border. While these actions primarily impact immigration laws, several...more

King & Spalding

New Ten-Year Statute of Limitations for Sanctions Violations

King & Spalding on

Implications Related to the Doubling of the Statute of Limitations for Civil and Criminal Violations of Two Primary Sanctions Authorities - SUMMARY - On April 24, 2024, President Biden signed into law a foreign military...more

Jones Day

Cryptocurrencies and Risk Under the Antiterrorism Act

Jones Day on

In Short - The Situation: Terrorists may be increasingly turning to cryptocurrencies to evade sanctions and finance terrorist acts, as recent prosecutions and reports suggest. Under the Antiterrorism Act ("ATA"), as...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - April 2023 - OFAC Enforcement Trends – Lack of Due Diligence in Mergers and Acquisitions

With roughly 12,000 names now associated with the Specially Designated Nationals and Blocked Persons List (“SDN”), layered sanctions on activities with Russia, and growing sanctions on China activities, U.S. sanctions have...more

American Conference Institute (ACI)

Compliance measures to address sanctions enforcement: ‘the new FCPA’

In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more

K2 Integrity

Sanctions Against Russia: Understanding the Evolving Picture and How to Respond

K2 Integrity on

...Since the start of the invasion of Ukraine by Russian forces on February 24, the United States (U.S.), United Kingdom (UK), and the European Union (EU) have led a global sanctions campaign against Russia that has been...more

WilmerHale

OFAC Enforcement Actions Highlight Risks to Software Providers & MSBs

WilmerHale on

On April 29, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies over their apparent violations of its regulations. The...more

Womble Bond Dickinson

Key Developments in US Sanctions

Womble Bond Dickinson on

Global supply chains have been greatly disrupted by the COVID-19 pandemic, sending companies scrambling to find both new sources of supplies and new customers for their products. But even as businesses struggle to find their...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - October 2017

ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - August 2017

ANTICORRUPTION DEVELOPMENTS - MTS Receives DOJ and SEC Declination Letters Concluding FCPA Investigations - On August 7, 2017, MTS Systems (MTS), a Minnesota based maker of test systems and industrial position...more

K&L Gates LLP

International AML Enforcement in 2017 Expected to Target Consumer-Due-Diligence Programs, Gaming Entities, Prepaid Cards, Digital...

K&L Gates LLP on

Over the past two years, financial regulatory bodies in the United States and Europe have increasingly emphasized consumer due diligence (“CDD”) by financial institutions as a means to combat money laundering and terrorist...more

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