There are some things you learn best in calm, and some in storm. Willa Cather I know I sound like a broken record. The Justice Department’s white collar criminal enforcement has been trending down over the last few years. The reasons for that are unclear — is it resources, difficulty and length of investigations or just lack of initiative? Whatever the cause may be, one...
As we have noted on numerous occasions, the U.S. Russia Sanctions and Export Control Program is unprecedented and a compliance challenge for all organizations. In another unprecedented action, the Justice Department and the Departments of Commerce and Treasury issued a Joint Compliance Note (“JCN”) on the importance of compliance with the Russia Sanctions and Export Control requirement, which provides important descriptions of red flags and...
The Justice Department continues to push on white collar corporate enforcement, and the intersection of national security sanctions and export controls with corporate criminal enforcement. Last week, Lisa Monaco, DOJ’s Deputy Attorney General, and Kenneth Polite, Assistant Attorney General of DOJ’s Criminal Division, delivered one-two punches in separate speeches at the ABA White Collar Conference in Miami, Florida. In their speeches, DOJ announced new enforcement...
