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Basics of How to Respond a US Sanctions or Export Control Civil and Criminal Enforcement Action
By Farhad Alavi (Washington) & Sam Amir Toossi (New York)
The Biden Administration has been steadfast in its imposition of Russian sanctions in response to their invasion of Ukraine. These newly imposed sanctions are merely the latest example of how the U.S. uses its various sanctions programs to carry out its foreign policy objectives. With the recent expansion of the Russian sanctions program, enforcement has become a top priority at the Department of Justice. In fact, at a recent meeting of the White Collar Crime Institute at the New York Bar Association, Deputy Attorney General Lisa Monaco stated, “one way to think about this is sanctions being the new FCPA,” one of the DOJ’s top enforcement priorities in the world of corporate enforcement.[1]
This article summarizes the legal framework surrounding sanctions enforcement and provides an overview of what companies and individuals should do to prevent sanctions violations. This article also outlines various strategies that companies and individuals can employ and implement if they fall under regulatory investigation.
By Farhad Alavi (Washington) & Sam Amir Toossi (New York)
The Biden Administration has been steadfast in its imposition of Russian sanctions in response to their invasion of Ukraine. These newly imposed sanctions are merely the latest example of how the U.S. uses its various sanctions programs to carry out its foreign policy objectives. With the recent expansion of the Russian sanctions program, enforcement has become a top priority at the Department of Justice. In fact, at a recent meeting of the White Collar Crime Institute at the New York Bar Association, Deputy Attorney General Lisa Monaco stated, “one way to think about this is sanctions being the new FCPA,” one of the DOJ’s top enforcement priorities in the world of corporate enforcement.[1]
This article summarizes the legal framework surrounding sanctions enforcement and provides an overview of what companies and individuals should do to prevent sanctions violations. This article also outlines various strategies that companies and individuals can employ and implement if they fall under regulatory investigation.
