DOJ Repeats Warnings on Aggressive Criminal Enforcement of Sanctions and Export Controls
As everyone knows, I tend to repeat myself — DOJ does as well. Over the past year, DOJ has warned global companies — over and over — about the coming criminal enforcement storm against companies for sanctions and export control violations. Deputy Attorney General Monaco coined the phrase — “the new FCPA,” to reiterate that companies would be prosecuted akin to FCPA enforcement, meaning that...