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Voluntary Disclosure

Proskauer - Government Contractor Compliance...

OFCCP Seeks Voluntary Disclosures from Federal Contractors on EO 14173 Compliance

On June 27, 2025, Office of Federal Contract Compliance Programs (“OFCCP”) Director Catherine Eschbach issued a letter announcing that OFCCP is “providing all federal contractors withthe opportunity to volunteer informationin...more

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

Hogan Lovells

Back in Business? What the DOJ’s FCPA reset means for the SFO and UK companies

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On 9 June 2025, the U.S. Department of Justice (DOJ) published revised guidance for the enforcement of the Foreign Corrupt Practices Act (FCPA). Much attention has been paid to the apparent “unpausing” of enforcement...more

DCI Consulting

[Webinar] To Submit or Not Submit: How Federal Contractors Should Respond to OFCCP’s Voluntary Information Request - July 10th,...

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On June 27, 2025, OFCCP Director Catherine Eschbach sent a letter to federal contractors. In this letter, the Director requested that federal contractors voluntarily submit information to the agency regarding how they have...more

A&O Shearman

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

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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

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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

Constangy, Brooks, Smith & Prophete, LLP

OFCCP invites contractors to disclose efforts to wrap up EO 11246 compliance

File under “thanks, but no thanks.” In an open letter to contractors, Catherine Eschbach, Director of the Office of Federal Contract Compliance Programs, offers contractors the opportunity to explain how they have wound...more

Paul Hastings LLP

DOJ’s M&A Safe Harbor Highlights Importance of Post-Close Due Diligence and Integration

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On June 16, the U.S. Department of Justice’s (DOJ’s or Department’s) National Security Division (NSD or Division) announced they had declined to prosecute the private equity firm White Deer Management LLC for violations of...more

The Volkov Law Group

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

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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

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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

The EU’s CSRD and CSDDD Compliance Playbook Is Being Rewritten (Again)

European policy-makers are moving swiftly to scale back the scope and burden of corporate sustainability reporting. Specifically, in recent weeks, two parallel developments—one political, the other technical—have introduced...more

Jackson Lewis P.C.

OFCCP Invites Voluntary Disclosures from Federal Contractors Regarding Executive Order 14173

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In a letter dated June 27, 2025, sent to federal contractors and posted on its website, the Office of Federal Contract Compliance Programs (OFCCP) announced it is providing federal contractors the option to voluntarily submit...more

The Volkov Law Group

DOJ’s Coordinated Resolution with Unicat Resolves OFAC, BIS and CBP Violations (Part II of III)

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DOJ’s Unicat resolution is a perfect example of the new trade enforcement reality under the Trump Administration.  DOJ spearheaded a global resolution of sanctions, customs and export controls violations, while declining to...more

The Volkov Law Group

Unicat Settles with DOJ and Resolves Sanctions, Export Controls and Customs Violations Applying Voluntary Disclosure Policy in M&A...

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In an interesting enforcement action reflecting the Administration’s priority on sanctions, export and customs enforcement, DOJ announced a global resolution with DOJ, OFAC, BIS and CBP and Unicat Catalyst Technologies...more

Hogan Lovells

The NSD declines prosecution for the first time under its M&A Policy

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On June 16, 2025, the U.S. Department of Justice (DOJ) publicly announced that it had declined to prosecute White Deer Management LLC (White Deer) and certain affiliates for violations of sanctions law and related conduct....more

Troutman Pepper Locke

DOJ’s Revised Self-Disclosure Policy May Offer Companies More Certainty

Troutman Pepper Locke on

Last month, the DOJ Criminal Division (Division) revised its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), introducing several potentially significant changes intended to further incentivize companies to...more

Wiley Rein LLP

DOJ’s Approach to White Collar Enforcement: Target Those Who Harm U.S. Interests While Minimizing Collateral Damage

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The U.S. Department of Justice (DOJ) recently announced Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA). The June 9 memorandum from Deputy Attorney General Todd Blanche instructs...more

Morrison & Foerster LLP

DOJ Issues First-Ever Declination Under Corporate Disclosure M&A Policy

On June 16, 2025, the Department of Justice (DOJ) National Security Division (NSD) announced that it declined to charge private equity firm White Deer Management LLC (“White Deer”) and its affiliates after the company...more

DLA Piper

Private Equity Acquirer Avoids “Unicat-astrophe” Following Voluntary Disclosures to the DOJ

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The US Department of Justice (DOJ) announced that it has formally declined to prosecute private equity firm White Deer Management LLC (White Deer) and certain of its affiliates in connection with criminal violations of US...more

White & Case LLP

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

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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

Baker Donelson

Update: DOJ Issues Guidelines for Protectionist FCPA Enforcement

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In February, the White House issued an Executive Order "pausing" Foreign Corrupt Practices Act (FCPA) enforcement for 180 days, to "further American economic and national security."1 On June 9, Deputy Attorney General Todd...more

Alston & Bird

A DOJ Private Equity Declination and Its Lessons for Acquirers and Targets

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The DOJ declined to prosecute a private equity firm for its portfolio company’s pre-acquisition sanctions and export violations, marking the first application of the National Security Division’s M&A Policy. Our White Collar,...more

Eversheds Sutherland (US) LLP

DOJ declines prosecution for PE firm after post-acquisition voluntary self-disclosure

On June 16, 2025, the Department of Justice (DOJ) National Security Division (NSD) and the US Attorney’s Office for the Southern District of Texas announced the first declination of prosecution for an acquirer that...more

Rivkin Radler LLP

The Latest Refinements to DOJ’s White Collar Enforcement Policy

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Last month, the head of the Criminal Division of the U.S. Department of Justice (DOJ), Matthew R. Galeotti, issued a Memorandum outlining DOJ’s enforcement priorities and policies for prosecuting white-collar crime,...more

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