On February 20, 2025, the US Department of State designated several international cartels and transnational criminal organizations as Foreign Terrorist Organizations (“FTOs”) pursuant to section 219 of the Immigration and Nationality Act and as Specially Designated Global Terrorists (“SDGTs”) pursuant to Executive Order (“EO”) 13224. These parties have been designated for “threaten[ing] the safety of the American people, the security of the United States, and the stability of the international order in the Western Hemisphere,”…
As risks and complexities for sanctions investigations have grown, so has the number of regulators and enforcement agencies bringing enforcement actions, and not just in the United States. Enforcement agencies around the world are becoming more active, with a focus on enforcing sanctions and export controls targeting Russia since its February 2022 invasion of Ukraine. There has been a particular uptick in public enforcement of EU sanctions targeting Russia by various EU Member States in…
On March 7, 2024, the US Department of Justice (“DOJ”) National Security Division (“NSD”) published a revised Enforcement Policy for Business Organizations (“Enforcement Policy”). The Enforcement Policy was first issued by the NSD on December 13, 2019 and subsequently updated March 1, 2023. Our blog post discussing the original policy is here. In these latest updates NSD has not altered the core components of the Enforcement Policy, which provides that when a company (1) voluntary…
On July 26, 2023, the US Departments of Treasury, Commerce, and Justice published a Tri-Seal Compliance Note on the voluntary self-disclosure (“VSD”) of potential violations of US sanctions, export controls, and other national security laws (the “VSD Note”). This publication is the second Tri-Seal Compliance Note issued by the agencies and continues the enforcement focus on the sanctions and export control measures targeting Russia in particular and national security concerns more generally. The first Tri-Seal…