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Global Investigations & Compliance Review

OFAC Guidance on the Statute of Limitations Extension

The President’s signing of the 21st Century Peace through Strength Act (the “Act”)[1] on April 24, 2024 marked one of the most significant expansions of the sanctions enforcement authority of the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). For many decades OFAC’s civil enforcement actions have been limited to five years...… Continue Reading The post OFAC Guidance on the Statute of Limitations Extension appeared first on Global Investigations & Compliance Review.

July 2024 | Blog

Global Investigations & Compliance Review

New 10-Year Statute of Limitations for U.S. Sanctions Violations

On April 24, 2024, President Biden signed into law H.R. 815[1], an emergency supplemental appropriations law, that provides $95.3 billion in military aid to U.S. allies and requires the divestiture of certain social media applications. While much of the discussion surrounding the new law focuses on the emergency foreign aid funding for Ukraine, Israel, and...… Continue Reading The post New 10-Year Statute of Limitations for U.S. Sanctions Violations appeared first on Global Investigations & Compliance Review.

May 2024 | Blog

Global Investigations & Compliance Review

U.S. Sanctions Review: A Recap of OFAC’s Recent Enforcement Actions (Second Half 2023)

The second half of 2023 saw eight enforcement actions from the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”).  These actions reflect a range of penalties, industries, sanctions programs, conduct, and lessons learned.  Below are some highlights from OFAC’s enforcement releases and settlement agreements. Penalties OFAC imposed a total of $984,851,289.90 in penalties...… Continue Reading The post U.S. Sanctions Review: A Recap of OFAC’s Recent Enforcement Actions (Second Half 2023) appeared first on Global Investigations & Compliance Review.

January 2024 | Blog

Global Investigations & Compliance Review

United States Departments of Treasury, Commerce, and Justice Issue “Tri-Seal” Compliance Note on Voluntary Self-Disclosures of Potential Violations

Earlier this year, we published a post on the first Tri-Seal Compliance Note (“First Note”) issued by the United States Department of Justice’s (“DOJ”) National Security Division (“NSD”), the Department of Commerce’s Bureau of Industry and Security (“BIS”), and the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”).[1]  When issuing the First Note,...… Continue Reading The post United States Departments of Treasury, Commerce, and Justice Issue “Tri-Seal” Compliance Note on Voluntary Self-Disclosures of Potential Violations appeared first on Global Investigations & Compliance Review.

August 2023 | Blog

Global Investigations & Compliance Review

Department of Justice Continues to Stress Importance of Robust Corporate Compliance Programs

At last week’s American Bar Association’s 38th Annual National Institute on White Collar Crime, both Deputy Attorney General Lisa O. Monaco and Assistant Attorney General Kenneth A. Polite, Jr. provided additional insight into the DOJ’s continued focus on corporate criminal enforcement. Our previous blog post details the expansion of DOJ’s National Security Division and the...… Continue Reading The post Department of Justice Continues to Stress Importance of Robust Corporate Compliance Programs appeared first on Global Investigations & Compliance Review.

March 2023 | Blog

Global Investigations & Compliance Review

Department of Justice Initiatives Prioritize Economic Sanctions Enforcement

On March 2, 2023, the Department of Justice announced several new initiatives that prioritize the investigation and enforcement of economic sanctions evasion, export control violations, and similar economic crimes.  Deputy Attorney General Lisa Monaco announced a “surge of resources to address a troubling trend: the intersection of corporate crime and national security.”  In particular, DOJ’s...… Continue Reading The post Department of Justice Initiatives Prioritize Economic Sanctions Enforcement appeared first on Global Investigations & Compliance Review.

March 2023 | Blog

Global Investigations & Compliance Review

Congress Continues to Expand Bank Secrecy Act Whistleblower Program

The Consolidated Appropriations Act, 2023 amended the Bank Secrecy Act’s whistleblower provisions, setting a floor on the monetary award a whistleblower may receive, allowing whistleblowers to receive awards relating to successful enforcement of certain economic sanctions statutes such as the International Emergency Economic Powers Act, and establishing a fund from which to pay whistleblowers.  Following...… Continue Reading The post Congress Continues to Expand Bank Secrecy Act Whistleblower Program appeared first on Global Investigations & Compliance Review.

January 2023 | Blog

Global Investigations & Compliance Review

DOJ’s Criminal Division Announces Revised Corporate Enforcement Policy

On January 17, 2023, Assistant Attorney General for the Criminal Division (“AAG”) Kenneth A. Polite, Jr. announced significant revisions to the U.S. Department of Justice, Criminal Division, corporate criminal enforcement policy (“CEP”).[1] The new CEP changes offer additional incentives to companies for voluntary self-disclosures, cooperation, and remediation.  The new CEP reflects an increased emphasis on...… Continue Reading The post DOJ’s Criminal Division Announces Revised Corporate Enforcement Policy appeared first on Global Investigations & Compliance Review.

January 2023 | Blog

Global Investigations & Compliance Review

Analysis of Expected and Recent Developments in Congressional Oversight & Investigations in the 118th Congress

This month, the 118th Congress convened in Washington, D.C., ushering in a return to divided government. Republicans now hold a narrow majority in the House of Representatives, while Democrats have retained their slim Senate majority. With few opportunities likely for bipartisan compromise, Congress is expected to engage in more frequent and more partisan congressional investigations....… Continue Reading The post Analysis of Expected and Recent Developments in Congressional Oversight & Investigations in the 118th Congress appeared first on Global Investigations & Compliance Review.

January 2023 | Blog

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