Understanding the Latest DOJ Changes to Corporate Prosecutions
The Justice Insiders Podcast: Self-Disclosure, Cooperation, and the Hazards of Knowing Too Little
5 Key Takeaways | 2024 Emerging Trends: Delaware Unclaimed Property VDA and Multistate Audits
The Presumption of Innocence Podcast: Episode 44 - A Recipe for Litigation: The Simmering Conflict Surrounding ERC Claims
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
FCPA Survival Guide: Step 1 - Self-Disclosure
Episode 316 -- DOJ Announces New Whistleblower Policy
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
The Presumption of Innocence Podcast: Episode 28 - Under the Microscope: Examining the Future of the ERC
Episode 289 -- Justice, Commerce and Treasury Issue Joint Notice on Voluntary Disclosure
What DAG Lisa Monaco's Speech Means for Compliance Programs
Torres Talks Trade Podcast- Episode 13- When Government Agencies Come Knocking
Torres Talks Trade Episode 11 on Sanctions and Export Enforcement Cases by DOJ
The Justice Insiders Podcast: The DOJ Wants You! - Part II: Voluntary Disclosures
Williams Mullen's Comeback Plan: Part I – State & Local Tax (SALT) Compliance During COVID-19: What to Do When You’re Behind
Anti-corruption & international risk developments
Podcast - Risk Management: Impact of Revised FCPA Policy on International Risk Management Programs
Podcast - Risk Management: Revised FCPA Corporate Enforcement Policy
FCPA Compliance Report-Episode 366 Jonathan Marks on performing and using a root cause analysis
This Week in FCPA-Episode 56
Córdoba Music Group LLC (Córdoba), a manufacturer of musical instruments based in California, has agreed to pay $41,591 to settle its civil liability for violations of sanctions on Iran. On nine occasions, Córdoba shipped...more
Looking for something more advanced than your average export controls conference? Go beyond the basics at ACI’s 2nd Annual Advanced Forum on Global Export Controls. This premier event offers cutting-edge insights and...more
As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more
The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for...more
Key Points - On May 21, 2024, the DOJ announced its first ever declination under the NSD’s updated Enforcement Policy, declining to prosecute Sigma-Aldrich Inc., d/b/a MilliporeSigma (a subsidiary of Merck KGaA, Darmstadt,...more
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
Companies and their executives can reduce Department of Justice (DoJ), OFAC, and Commerce Department risks (and liability) by understanding and respecting the relationship between economic sanctions, voluntary...more
When it comes to OFAC sanctions violations, honesty is the best policy. Promptly and voluntarily disclosing violations upon their discovery can pay serious dividends. ...more
Companies faced with the decision of whether to voluntarily self-report sanctions breaches to law enforcement or sanctions enforcement agencies in the UK and the US can take some measure of comfort from recent comments made...more
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
On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more
The Department of Justice is pushing its commitment to voluntary disclosure programs. Companies, however, are not lining up at DOJ’s door. The balance between sitting tight or voluntary disclosures requires care....more
U.S. companies with international clients or customers have to comply with far more laws and regulations than companies that only operate domestically. These include laws and regulations enforced by the U.S. Office of Foreign...more
Comtech Telecommunications (“Comtech”) and Comtech EF Data Corp. (“EF Data”) agreed to pay OFAC $894,111 for violations of the Sudan Sanctions Program. ...more
On July 8, the U.S. Department of the Treasury announced a settlement with Amazon.com, Inc., related to the company's potential civil liability for apparent violations of multiple sanctions programs resulting from...more
A government inquiry can result in serious consequences for a company or individual. Our new podcast series, Voluntary Disclosure—brought to you by the lawyers in our investigations, enforcement, and white collar practice—is...more
In 2019, the Department of Treasury’s Office of Foreign Asset Control (OFAC) issued important guidance on sanctions compliance programs. OFAC’s guidance sets out new and prescriptive requirements for sanctions compliance...more
• Actions underscore long arm of U.S. sanctions jurisdiction • Voluntary disclosures and cooperation can lead to significant penalty reductions • Facilitation of a violation is treated the same as a direct violation ...more
Report on Supply Chain Compliance 3, no. 2 (January 23, 2020) - The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), the primary U.S. government agency that administers U.S. economic sanctions, was busy...more
On December 13, 2019, the U.S. Department of Justice (“DOJ”) issued a new policy for companies that voluntarily disclose potential criminal violations of U.S. sanctions and export control laws to the DOJ’s National Security...more
• On December 13, 2019, the Department of Justice (DOJ) revised and re-issued its “Export Controls and Sanctions Policy for Business Organizations” (the “Revised Policy”) to “provide greater clarity for companies faced with a...more
• Penalties imposed for violations of U.S. sanctions on Russia and Ukraine • Violations identified during pre-acquisition due diligence on contractor • Denied persons screening was conducted but missed prohibited...more
•Many medical products can be exported to Iran – so long as a license is obtained •Imposition of successor liability underscores importance of pre-transaction due diligence •OFAC enforcement, as in the past, continues...more