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…
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…
On April 15, 2020, the US Departments of State, Homeland Security, and the Treasury (“Treasury”), and the Federal Bureau of Investigation issued an advisory warning about the cyber threat posed by North Korea, calling particular attention to banks and other financial institutions (“Advisory”). The Advisory (i) highlights North Korea’s malicious cyber activities across the globe, (ii) identifies and recommends measures to counter the cyber threat, including cybersecurity best practices, and (iii) summarizes potential enforcement actions…
In a continuing effort to pressure and isolate North Korea by targeting entities and individuals in third countries, on Tuesday, August 22, 2017, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) and US Justice Department (“DOJ”) announced sanctions and a civil forfeiture action, respectively, targeting Chinese and Russian entities accused of directly or indirectly assisting or supporting North Korea’s nuclear and ballistic missile programs. China is North Korea’s primary trading partner and these actions appear to be an effort, in part, to ramp up pressure on China to assist in curtailing its neighbor’s nuclear ambitions.