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…

In the high-stakes world of sanctions investigations, where data privacy meets sanctions regimes, companies and practitioners must navigate both domestic and international legislation while ensuring compliance with regulatory agencies. In the complex landscape of sanctions investigations and the need to identify and collate documents that are relevant to the investigation, data protection plays a crucial role. The initial phase of a sanctions investigation often involves fact finding in order to establish the complete picture of…