Last year, the Department of Justice warned global companies of a new, aggressive strategy for enforcement of trade sanctions and export controls. Deputy Attorney General Lisa Monaco stated that sanctions and export enforcement constituted “The New FCPA.”

DOJ, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) and the Department of Commerce’s Bureau of Industry and Security (“BIS”) have joined forces to aggressively enforce sanctions and export rules. In April 2023, BIS announced a $300 million settlement with Seagate. It was BIS’ largest administrative penalty. Also, DOJ and OFAC announced a $659 million penalty for British American Tobacco for violations of the North Korea Sanctions Program. Both of these actions represented a new, aggressive approach to corporate enforcement for sanctions and export control requirements.

In this Episode, Michael Volkov reviews the important aspects of DOJ, OFAC and BIS enforcement actions.