Learning Objectives

  • DOJ has warned global companies of a new, aggressive strategy for enforcement of trade sanctions and export controls intended to vindicate and protect national security interests.  To back up its warning, DOJ has assigned over 25 new prosecutors to target corporations for criminal prosecution of sanctions violations.
  • DOJ’s Deputy Attorney General Lisa Monaco stated that sanctions and export enforcement constituted "The New FCPA.”
  • Last year, DOJ and the Department of Treasury’s Office of Foreign Asset Control (“OFAC”) announced a $659 million penalty for British American Tobacco for violations of the North Korea Sanctions, and the Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed its largest administrative penalty ever by charging Seagate $300 million for violations of its Huawei export controls.  
  • Companies have to prioritize sanctions and export control compliance and build effective risk mitigation strategies.
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