In this episode of Corruption, Crime and Compliance, Michael Volkov explains why acquiring a sanctions violation is even riskier than buying an FCPA problem: under programs like Cuba and Iran, U.S. ownership of a foreign target can itself create sanctions jurisdiction on closing day, turning previously lawful foreign business into violations overnight. Drawing on OFAC’s 2019 Framework for Compliance Commitments, which calls for compliance involvement in deals and post-closing audit and testing, he walks through enforcement actions including Unicat and White Deer (the first DOJ declination of an acquirer under its M&A policy, even as the target paid millions), Murad and Unilever, Kollmorgen, Stanley Black & Decker, AppliChem and Illinois Tool Works, First Bank and J.C. Flowers, Key Holding, and S&P Global, with Berkshire Hathaway’s Iscar Turkey matter as a companion parent-liability case. Volkov closes with a deal playbook: sanctions-specific diligence beyond seller representations, targeted indemnities, day-one written notice to the target, replacing management certifications with real transaction testing, escalating every red flag, and building integration around DOJ’s 180-day disclosure and one-year remediation windows.