News & Analysis as of

Sanctions Department of Justice (DOJ)

BakerHostetler

Antitrust Sanctions: The Duty to Preserve Chats

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On August 5, 2024, District Judge Amit P. Mehta (U.S. District Court, District of Columbia) ruled in United States v. Google LLC that Google violated §2 of the Sherman Act by monopolizing the internet search engine market....more

White & Case LLP

Sanctions move up the agenda for lenders and borrowers

White & Case LLP on

Compliance with sanctions regimes has been a priority for debt markets. Amid rising geopolitical tensions, the stakes for lenders and borrowers are higher than ever - Intensifying geopolitical tensions and the US...more

Benesch

White Collar Quarterly Report - August 2024

Benesch on

In 2023, the number of federal corporate prosecutions remained far below the 25-year average after two consecutive years of increases. ..The DOJ’s Fraud Section secured just $690 million in penalties across eight...more

Guidepost Solutions LLC

Crypto Crackdown: 8 Key BSA/AML Fundamentals for FinTechs

In June 2024, multiple state regulators took joint action against Plutus Financial, Inc (Abra) ordering Abra to cease and desist certain operations in the U.S. and reimburse customers of virtual assets valued at $81.1 million...more

Foley Hoag LLP

Foley Hoag 2024 White Collar Year In Preview Series

Foley Hoag LLP on

The government had another busy year in 2023, investigating and prosecuting healthcare fraud cases on multiple fronts. Contending with the enormous healthcare crises of the now-concluded COVID-19 pandemic and the ongoing...more

Foley Hoag LLP

Developments in U.S. International Trade Laws Since the Start of 2023 and What to Expect for the Rest of 2024

Foley Hoag LLP on

Throughout 2023 and early 2024, we continue to witness deepening geopolitical and economic divides globally. The U.S. and its allies (most significantly the EU and the G7), spurred on by Russia’s war in Ukraine, continue to...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – March 2024 Update

You are reading the March 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. Overview...more

WilmerHale

U.S. Agencies Caution Foreign-Based Persons on Extraterritorial Reach of U.S. Sanctions and Export Control Regulations

WilmerHale on

On March 6, 2024, the U.S. Departments of the Treasury, Commerce, and Justice jointly issued a Tri-Seal Compliance Note titled “Obligations of Foreign-Based Persons to Comply with U.S. Sanctions and Export Control Laws”...more

Sheppard Mullin Richter & Hampton LLP

Guidance to Foreign Companies on Export Controls and Sanctions: Departments of Commerce, Treasury, and Justice Issue Tri-Seal...

On Wednesday, March 6, 2024, the Department of Commerce, Department of the Treasury and Department of Justice issued another Tri-seal Compliance Note, focusing this time on the obligations of foreign based persons complying...more

NAVEX

Risk & Compliance as a Strategic Imperative for the Board

NAVEX on

In an era marked by heightened global regulatory scrutiny and enforcement, the landscape of risk and compliance is undergoing an evolution making the strategic imperative for effective, risk-based compliance initiatives...more

Torres Trade Law, PLLC

Trade Violations Under the False Claims Act

On February 7, the U.S. Department of Justice (DOJ) announced that settlements and judgements under the False Claims Act (FCA) exceeded $2 billion for the 2022 fiscal year. The 2022 fiscal year also had the second-highest...more

Skadden, Arps, Slate, Meagher & Flom LLP

Court Victory for Treasury and Indictment of Tornado Cash Founders Highlights AML and Sanctions Risks for DeFi Crypto Platforms

In a long-awaited decision involving the cryptocurrency “mixer” Tornado Cash, a U.S. district court on August 17, 2023, upheld the broad authority of the Department of the Treasury’s (Treasury’s) Office of Foreign Assets...more

Skadden, Arps, Slate, Meagher & Flom LLP

OFAC Enforcement Action Emphasizes the Importance of Whistleblower Programs

On August 16, 2023, OFAC announced a $660,594 settlement with Construction Specialties Inc. (CS) for alleged violations of the Iranian Transactions and Sanctions Regulations (ITSR). OFAC found that CS’s wholly controlled...more

Fenwick & West LLP

New Official Guidance on Voluntary Self-Disclosure of Trade Control Violations

Fenwick & West LLP on

On July 26, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) and the U.S. Department of Justice (DOJ) released joint...more

Thomas Fox - Compliance Evangelist

Corruption, Crime and Compliance - “The New FCPA”: Sanctions and Export Control Enforcement and Compliance

Unprecedented sanctions and export control enforcement changes are imminent as the U.S. government amplifies its focus on national security and corporate compliance. In this episode of Corruption, Crime, and Compliance,...more

Thomas Fox - Compliance Evangelist

Corruption, Crime, & Compliance - Five Steps to Enhance Your Sanctions Compliance Program

Is your business prepared to effectively manage and mitigate the risks associated with sanctions compliance in today’s global economic landscape? In today’s increasingly interconnected global economy, sanctions compliance is...more

A&O Shearman

U.S. Cracks Down on Sanctions Evasion

A&O Shearman on

On March 2, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), the Department of the Treasury’s Office of Foreign Asset Control (OFAC) and the Department of Justice issued a joint compliance note...more

Torres Trade Law, PLLC

Trade Violations Under the False Claims Act

On February 7, 2023, the U.S. Department of Justice (“DOJ”) announced that settlements and judgements under the False Claims Act (“FCA”) exceeded $2 billion for the 2022 fiscal year. The 2022 fiscal year also had the...more

Kohn, Kohn & Colapinto LLP

The Anti-Money Laundering Whistleblower Improvement Act: Justice for Whistleblowers; No Peace for Russian Oligarchs

A two-year campaign to create an effective law incentivizing whistleblowers to report money laundering and sanctions busting has ended with a stunning and surprise victory for whistleblowers. It started in December 2020 when...more

Kohn, Kohn & Colapinto LLP

Danske Bank Scandal Proves Need for AML Whistleblower Law

Nearly 10 years after former employee Howard Wilkinson blew the whistle on Danske Bank, the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have issued over $2 billion in penalties against the...more

Katten Muchin Rosenman LLP

US Moves to Seize Aircraft for Apparent Violation of Export Controls

Key Points - - The US Department of Justice reported that it obtained a warrant for the seizure of a Boeing 737-7EM aircraft for the alleged violation of US export controls on Russia (rather than because of ownership of...more

Guidepost Solutions LLC

Guidepost in Motion EP25: State of Compliance with Alixandra Smith Part 2

Eric T. Young and Alixandra Smith, deputy chief of the Criminal Division at the U.S. Attorney’s Office for the Eastern District of New York, continue their discussion about the Department of Justice’s expectations of...more

Foley Hoag LLP

Department of Commerce’s Bureau of Industry and Security Eyes Enforcement and Voluntary Disclosure Review Policy Changes

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June 23, 2022 Key Takeaways: In two recent speeches, Matthew Axelrod, Assistant Secretary for Export Enforcement at the Department of Commerce’s Bureau of Industry and Security (“BIS”), has signaled policy changes related to...more

Cranfill Sumner LLP

DOJ Announces Early Targets of Task Force KleptoCapture, Elite Anti-Money Laundering Initiative Established to Halt Russian...

Cranfill Sumner LLP on

In late May, a court in the Pacific island nation of Fiji upheld on appeal the detention of the 348-foot Amadea, reportedly owned by Russian oligarch Suleiman Kerimov, whose wealth largely derives from his 76% stake in...more

Proskauer - Minding Your Business

The Sound of “Silent Attorneys”: DOJ Alleges Google Fakes Attorney-Client Privilege by CCing Lawyers Who Never Respond

If a request for legal advice goes unanswered, is it really a request for legal advice? According to the U.S. Department of Justice and several state attorneys general (“DOJ Plaintiffs”) in an antitrust action against...more

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