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…
On 22 February 2023, the US Department of Justice (DOJ) announced a new voluntary self-disclosure policy for corporate criminal enforcement in all United States Attorneys’ Offices (USAOs) around the country. USAOs are often the front-line of DOJs enforcement efforts, prosecuting federal criminal cases in each of the 94 federal judicial districts across the country. This includes the prosecution of many criminal violations of US sanctions and export controls. Even when these cases are brought by one…
Last week, among the flurry of new sanctions announcements marking the one-year anniversary of Russia’s large-scale invasion of Ukraine, the G7 announced the creation of a new Enforcement Coordination Mechanism “to bolster compliance and enforcement of our measures and deny Russia the benefits of G7 economies.” The International Group of Seven (“G7”) is an intergovernmental forum whose members include the US, UK, Germany, France, Italy, Canada, and Japan, with the European Union as a “non-enumerated”…
On January 17, 2023, the US Department of Justice (“DOJ” or the “Department”) issued a revised version of its Criminal Division Corporate Enforcement Policy (“CEP”). The CEP sets out the Criminal Division’s approach to resolving cases with corporations. In particular, it addresses how the Criminal Division will credit companies which voluntarily disclose criminal conduct and cooperate during the investigation and resolution of the matter. Our analysis of the latest changes to the CEP can be…