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Corporate Counsel Department of Justice (DOJ) Export Controls

Akin Gump Strauss Hauer & Feld LLP

DOJ Announces First-Ever Corporate Declination Under National Security Division’s Voluntary Self-Disclosure Program

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

Fenwick & West LLP

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

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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

Orrick, Herrington & Sutcliffe LLP

Three Signs of a New Era in U.S. Export Controls and Sanctions Enforcement

In light of Russia’s invasion of Ukraine and intensifying strategic competition with China, the U.S. government is prioritizing enforcement of export controls and economic sanctions in unprecedented ways. We expect higher...more

Porter Hedges LLP

Update on Russian-Related Sanctions and Export Controls

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As the Russian invasion of Ukraine continues, the executive branch is mounting what the U.S. Department of Treasury (“Treasury”) calls a “historically unprecedented campaign of sanctions and export controls” aimed at...more

Kramer Levin Naftalis & Frankel LLP

Corporate Governance: 2022 Midyear Review

The first half of 2022 illuminated important trends in the corporate governance space. In recent months, there were notable developments in the enforcement of economic sanctions and export control measures, and the oversight...more

Sheppard Mullin Richter & Hampton LLP

Novel Sanctions Against Business-Related Services Connected to Russia and Additional Export Restrictions

On Sunday, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced novel and sweeping sanctions on specific categories of services in order to cripple Russia’s wartime capabilities and sanctioned key...more

BCLP

SAP Enforcement Action Underscores Importance of Ensuring Compliance Programs Address Considerations Associated with Business...

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On April 29, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of Treasury, and the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce announced settlements with German...more

The Volkov Law Group

SAP Reaches Broad Settlement and Agrees to Pay More Than $8 Million for Violations of Iran Sanctions Program (Part I of IV)

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In a precedent-setting agreement, the Justice Department, OFAC and the Bureau of Industry and Security announced a settlement with SAP SE for more than $8 million for numerous violations of the Iran Sanctions program....more

Thomas Fox - Compliance Evangelist

Airbus Settlement: Part 1 – Introduction

Last week, Airbus SE (Airbus) settled a long-standing corruption scandal by agreeing to enforcement actions in three countries; France, the United Kingdom and the US. The matter involved a massive, worldwide, long running...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

Jones Day

DOJ Policy Increases Incentives for Self-Reporting of Potentially Willful Trade Violations

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The Situation: The U.S. Department of Justice ("DOJ") has issued guidance revising its 2016 voluntary disclosure policy to provide companies stronger incentives to voluntarily self-report apparent potentially willful trade...more

A&O Shearman

DOJ Offers Non-Prosecution Agreements And No-Fines For Self-Reporting Export Control And Sanctions Violations

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In a development that could significantly affect how companies deal with possible export control and sanctions violations, the Department of Justice (“DOJ”) recently revised its policy regarding voluntary disclosure of trade...more

Orrick, Herrington & Sutcliffe LLP

DOJ Updates Its Approach to Encourage Voluntary Self-Disclosures of Export Control and Sanctions Violations

On December 13, 2019, the National Security Division (“NSD”) of the U.S. Department of Justice (“DOJ”) released a revised enforcement policy (“the Policy”) meant to encourage companies to voluntarily self-disclose potentially...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Provides Additional Incentives for Voluntary Self-Disclosures of Criminal Export Controls and Sanctions Violations

• 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

Morrison & Foerster LLP

DOJ Clarifies Incentives for Voluntary Self-Disclosures of Export Control and Sanctions Violations

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On December 13, 2019, the Department of Justice’s National Security Division (“NSD”) announced a revised policy to encourage voluntary self-disclosures (“VSDs”) of criminal violations of export control and sanctions laws. The...more

Faegre Drinker Biddle & Reath LLP

Important New Guidance for Companies Considering Voluntary Disclosures of Export Control and Sanctions Violations

On December 13, 2019, the U.S. Department of Justice’s National Security Division (NSD) issued important new policy guidance regarding voluntary disclosures of export control and sanctions laws violations. Among other things,...more

Vedder Price

Navigating Export Compliance and Anti-Discrimination: What DOJ’s Recent Settlement with Honda Aircraft Teaches Us

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The Department of Justice (DOJ) recently reached a settlement with Honda Aircraft Company, LLC (Honda Aircraft) resolving a claim that Honda Aircraft violated the Immigration and Nationality Act’s (INA) anti-discrimination...more

Morrison & Foerster LLP

DOJ Signals Once More that FARA Is an Enforcement Priority

In another indication of the U.S. Department of Justice’s increased focus on the Foreign Agents Registration Act (FARA), Assistant Attorney General John Demers announced that the Department is overhauling its FARA enforcement...more

Foley & Lardner LLP

The Twelve Compliance Steps Every Multinational Corporation Should Undertake in Light of Recent Trump Administration Enforcement...

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Over the last month, regulators with the Trump administration sent a loud message to companies subject to U.S. jurisdiction: Enforcement of laws governing international activities is alive and well and the laws will continue...more

BakerHostetler

2017 Mid-Year Cross-Border Government Investigations and Regulatory Enforcement Review

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Welcome to BakerHostetler’s 2017 Mid-Year Cross-Border Government Investigations and Regulatory Enforcement Review. This edition delivers news, analysis and insights into key developments in the cross-border investigations...more

Wilson Sonsini Goodrich & Rosati

ZTE Is Assessed $1.19 Billion in Penalties for Criminal and Civil Violations of Export Control and Economic Sanctions Laws and...

On March 7, 2017, the U.S. government announced that China's Zhongxing Telecommunications Equipment Corporation and its affiliate, ZTE Kangxun Telecommunications Ltd. (collectively "ZTE"), have agreed to a global settlement...more

Skadden, Arps, Slate, Meagher & Flom LLP

"US Announces Record-Setting Penalties for Violations of Export Controls and Economic Sanctions"

On March 7, 2017, the United States announced that China’s Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd. and their respective affiliates (collectively, ZTE) had agreed to a record...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Establishes Voluntary Self-Disclosure Program for Criminal Violations of U.S. Economic Sanctions and Export Controls

On October 2, 2016, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) established a formal, voluntary self-disclosure program for criminal violations of U.S. economic sanctions and export controls...more

BakerHostetler

Spoofing, Sports and the Panama Papers: BakerHostetler Offers Mid-Year Review of Cross-Border Government Investigations and...

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Halfway through 2016, the international community has seen a staggering variety of cross-border investigations and enforcement actions. Brexit, the release of the Panama Papers, allegations of widespread sports doping and the...more

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