Category: General

10 Jul, 2025

OFAC Imposes $608,825 Penalty on Key Holding, LLC for Apparent Violations of Cuban Sanctions Regulations

On July 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had entered into a settlement agreement with Key Holding, LLC (“Key Holding”), a privately held logistics and freight forwarding firm headquartered in Delaware, to resolve Key Holding’s potential civil liability for apparent violations of the Cuban Assets Control Regulations (“CACR”), 31 C.F.R. part 515. The apparent...

General

9 Jul, 2025

Cartel and TCO Due Diligence and Risk Factors (Part II of II)

Cartels and TCOs have entrenched themselves in legitimate industry sectors. In recent years, cartels and TCOs have adapted to market changes and new technologies. Many cartels and TCOs are disguising their ownership and financial interests through shell companies, sophisticated networks of third parties and legitimate businesses in real estate, construction, mining, agriculture, export/import, casinos, fintech platforms and finance. The Sinola Cartel in Mexico operates in...

General

8 Jul, 2025

Refocusing Due Diligence on Cartel and TCOs (Part I of II)

Companies face a dual challenge — the pressing need to unravel their supply chains, and the immediate task of recalibrating due diligence systems to examine potential presence of cartel and transnational criminal organizations (“TCOs”) in a company’s supply chain and distribution channel. The Justice Department has adjusted its enforcement priorities to elevate the importance of prosecuting cartels and TCOs. This initiative will involve a two-fold...

General

30 Jun, 2025

Lessons Learned from the Unicat Settlement (Part III of III)

The Unicat settlement provides some important insights into the Trump Administration’s direction on trade enforcement. It underscores the importance of voluntary disclosure, cooperation and remediation, the tri-part foundation of seeking a favorable enforcement resolution. Also, it emphasizes the importance of securing disclosure credit with the Justice Department since Unicat’s parent received a declination because of its early disclosure and complete cooperation. In stark contrast, the...

General

27 Jun, 2025

DOJ’s Coordinated Resolution with Unicat Resolves OFAC, BIS and CBP Violations (Part II of III)

DOJ’s Unicat resolution is a perfect example of the new trade enforcement reality under the Trump Administration. DOJ spearheaded a global resolution of sanctions, customs and export controls violations, while declining to prosecute the parent company that voluntarily disclosed the violations quickly after acquiring Catalyst. As detailed in court documents and in DOJ’s agreements with White Deer and Unicat, from approximately 2014 through 2021, Mani...

General

26 Jun, 2025

Unicat Settles with DOJ and Resolves Sanctions, Export Controls and Customs Violations Applying Voluntary Disclosure Policy in M&A Context (Part I of III)

In an interesting enforcement action reflecting the Administration’s priority on sanctions, export and customs enforcement, DOJ announced a global resolution with DOJ, OFAC, BIS and CBP and Unicat Catalyst Technologies (“Unicat”), under which Unicat agreed to pay forfeiture totaling $3,325,052.10, representing the proceeds of its violations of U.S. sanctions, export control and customs laws. In parallel resolutions coordinated between the Justice Department, the OFAC and...

General

24 Jun, 2025

OFAC Returns to Enforcement Scene — GVA Capital Pays $215 Million Penalty for Violations of Ukraine/Russia-Sanctions

The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been relatively quiet on the enforcement front. That is not unusual — every transition results in an enforcement hiatus. Sanctions enforcement is a priority for this Administration. As expected, the Justice Department will play a more evident role in the sanctions enforcement process. This a new development, when DOJ declines there may be disclosure of...

General

17 Jun, 2025

DOJ’s Fresh FCPA Enforcement Initiative — What’s New, What’s Not (Part II of II)

DOJ’s new approach to FCPA enforcement presents some interesting opportunities — the headlines from the DOJ FCPA Guidance Memo will bring some significant changes but at the same time some things will not change. Here is my list of what’s new and what’s the same. 1. Increased individual prosecutions and reduced emphasis on corporate prosecutions: The DOJ FCPA Guidance Memo prioritizes individual prosecutions and avoidance...

General

16 Jun, 2025

Justice Department Resumes FCPA Enforcement with New, Focused Guidance (Part I of II)

The Justice Department has returned to the FCPA enforcement arena — in a significant development, DOJ announced the resumption of FCPA enforcement, with a new set of enforcement guidance principles. The new guidance is an important statement governing FCPA investigations and prosecutions. The impact of this new approach will be significant — the precise scope of this renewed focus will depend on certain legal factors,...

Uncategorized

12 Jun, 2025

Supreme Court’s Wire Fraud Decision Raises Risks for Government Contractors

In a unanimous decision, the U.S. Supreme Court, in Kousisis v. United States affirmed a lower court’s decision upholding a conviction of federal wire fraud for inducing a victim to enter into a transaction under materially false pretenses, even if the defendant did not intend to cause the victim economic loss. The Supreme Court rejected the limiting of federal fraud cases to those where there...

Category: General

OFAC Imposes $608,825 Penalty on Key Holding, LLC for Apparent Violations of Cuban Sanctions Regulations

Cartel and TCO Due Diligence and Risk Factors (Part II of II)

Refocusing Due Diligence on Cartel and TCOs (Part I of II)

Lessons Learned from the Unicat Settlement (Part III of III)

DOJ’s Coordinated Resolution with Unicat Resolves OFAC, BIS and CBP Violations (Part II of III)

Unicat Settles with DOJ and Resolves Sanctions, Export Controls and Customs Violations Applying Voluntary Disclosure Policy in M&A Context (Part I of III)

OFAC Returns to Enforcement Scene — GVA Capital Pays $215 Million Penalty for Violations of Ukraine/Russia-Sanctions

DOJ’s Fresh FCPA Enforcement Initiative — What’s New, What’s Not (Part II of II)

Justice Department Resumes FCPA Enforcement with New, Focused Guidance (Part I of II)

Supreme Court’s Wire Fraud Decision Raises Risks for Government Contractors

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