Episode 352 — 2024 DOJ and OFAC Sanctions Enforcement and Compliance Review

How will your company withstand the heat of aggressive sanctions enforcement? Are you ready for the DOJ’s new priorities and OFAC’s expanding reach in 2025? In this episode of Corruption, Crime, and Compliance, Michael Volkov dives into the major sanctions enforcement trends from 2024 and the road ahead under the new Trump administration. From record-breaking DOJ prosecutions to OFAC’s innovative enforcement approaches, Michael explains how sanctions compliance is more critical than ever. He highlights the biggest cases of the year, uncovers common pitfalls that led to costly penalties, and outlines how businesses can navigate shifting regulatory priorities. Whether it’s integrating compliance in M&A or addressing the risks of evolving China and Iran sanctions, this episode delivers actionable insights for staying ahead of enforcement risks.

You’ll hear him discuss:

  • The DOJ’s record-breaking prosecution of 70 individuals in 2024 and predictions for a surge in enforcement in 2025.
  • OFAC’s evolving enforcement strategy, including secondary sanctions tied to U.S. dollar transactions and new compliance commitments.
  • Key lessons from major enforcement actions like SCG Plastics, Aotech, and MondoTV, which paid millions for sanctions violations.
  • The consequences of neglecting sanctions compliance during mergers and acquisitions, including inherited liabilities and enforcement risks.
  • Predictions for heightened scrutiny on trade with China, aggressive tariffs, and evolving Iran sanctions under the new administration.
  • How emerging issues like advanced computing, AI, and dual-use technologies are becoming focal points for sanctions enforcement.
  • The role of voluntary self-disclosure in mitigating penalties, with examples of companies that uncovered and corrected compliance gaps.

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