In an era where regulatory compliance is under intense scrutiny, the importance of a well-orchestrated response to trade and sanctions investigations cannot be overstated. An investigation may involve transactions occurring in multiple jurisdictions, laws of separate jurisdictions, and inquiries from (or disclosures to) multiple governmental authorities. Investigations may begin through an internal whistleblower or other internal discovery, which grants the company more discretion in directing the tempo and scope of the investigation. In other instances,…
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 January 30, 2024, Baker McKenzie, in partnership with the International Compliance Professionals Association, hosted a virtual fireside chat with Matthew Axelrod, the Assistant Secretary for Export Enforcement for Bureau of Industry and Security (“BIS”) in the US Commerce Department. The webinar attracted 3,200 registrations from across industry, with participants raising a wide variety of questions. In the discussion with Baker McKenzie partners Janet Kim (Washington, DC) and Sunny Mann (London), Assistant Secretary Axelrod discussed…
On January 22, 2024, the United States, United Kingdom, and Australia announced an additional round of coordinated sanctions designations of individuals, entities, and aircraft linked to Hamas and the Palestinian Islamic Jihad (“PIJ”). This coordinated action builds on recent joint US-UK and unilateral US designations. Our prior blog post on the October 18, 2023 US designations is available here. US Sanctions On January 22, 2024, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”)…