As we wrap up our series about sanctions investigations with this post, our Global Sanctions Investigation Group has blogged about key issues that companies should keep in mind as they tackle global sanctions investigations that are inherently high-risk matters. But do you need to passively wait around for the sanctions enforcement storm to batter your company and its trade compliance team? The simple answer is a resounding no. Companies worried about sanctions compliance and potential…
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…
In the midst of ongoing sanctions investigations and enforcement actions, companies are faced with yet another challenge: interested third-party stakeholders. Companies must decide who to share information with, what levels and types of information to share, how to share information, and how to mitigate the risks of loss of legal privilege, leaks, and triggering disclosure/reporting obligations by others. In this blog post, the Global Sanctions Investigations Group focuses on three critical third party stakeholders –…
As regulations evolve and enforcement intensifies, effective documentation of sanctions investigation results has never been more critical. Proper documentation is crucial not only for maintaining legal privileges and the confidentiality of sensitive information, but also for supporting legal defenses in potential regulatory enforcement in the future. Additionally, companies may have an obligation to disclose investigation results to their external auditors, shareholders, and other stakeholders (e.g., transaction counterparties), underscoring the importance of appropriate documentation to ensure…