Over the past eight weeks, following the announcement of the G7’s Sanctions Enforcement Coordination Mechanism, we have journeyed to our offices in each of the G7 members to ask our local sanctions experts to weigh in on what companies should know about sanctions enforcement in their jurisdiction — and what companies should be doing today to prepare — in light of the increase in sanctions enforcement, which we are already seeing on the ground. For…
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…