The Justice Department is about to undergo some fundamental changes.  The 2nd Trump Administration will take some initial broad strokes designed to increase accountability and control of prosecutors and laws enforcement.  The FBI The first on the chopping block is the FBI.  Under existing law, the FBI is a component of the U.S. Department of Justice, presumably under the control and oversight of the Attorney...

Each quarter, we send many of our clients a quarterly trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs. Click here to download the quarterly update for July. Below is a summary of events this past quarter: About the document: This handy one-pager is designed to be used by our clients to provide a quick...

We all know what a “core” sanctions violation looks like.  The heartland of such misconduct has been described on numerous occasions in OFAC enforcement actions and settlements.  In this environment, however, companies have to be aware of conduct that may still violate the law but is not necessarily in the “heartland” of misconduct. DOJ, OFAC and BIS are well aware of the broad reach of...

On May 17, 2024, Nevada-based DXC Technology Company (“DXC”)—a global IT services provider—officially filed its required annual 10-K Form with the U.S. Securities and Exchange Commission (“SEC”) indicating that previously-disclosed proceedings involving both the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) had been resolved. According to the SEC filing, DXC officially...

In this new aggressive era of sanctions and export controls enforcement, companies need to understand the potential risks that DOJ and/or OFAC may identify a company for sanctions investigation. In a global economy, investigators from various countries have built coordination procedures by which they share intelligence and possible leads among each other.  This phenomena has created a complex web of investigators who can identify relevant...

As always, I tend to repeat myself.  However, one important point needs to be repeated — DOJ is in the midst of launching an aggressive sanctions and export control program against corporations and individuals.  DOJ has warned everyone, repeated this message in various speeches and, most importantly, assigned the resources — 25 new federal prosecutors to enforce sanctions and export controls — to back up...

By: Alexander J. Cotoia currently serves as the Regulatory Compliance Manager at The Volkov Law Group, where he regularly advises the firm and its clients on the latest developments implicating trade compliance concerns. He may be reached at [email protected]; and Daniela Melendez, Associate at the Volkov Law Group she may be reached at [email protected] As we have repeatedly noted in the context of other blog...