The unprecedented speed of new economic sanctions against Russia should come as little surprise to those paying attention. But as compliance expert Michael Volkov explains, while more aggressive enforcement actions have been the norm for several years, the presence of new investigations means organizations must double down on their compliance commitments.
Hold onto your hats: While we are on the cusp of more Foreign Corrupt Practices Act (FCPA) enforcement actions, the Justice Department and Office of Foreign Assets Control (OFAC) are gearing up for real and significant sanctions enforcement actions. The die is cast, so here we go.
Deputy Attorney General Lisa Monaco was recently quoted as saying that sanctions enforcement is the “new FCPA.” This is not so surprising given the global crisis caused by Russia’s unprovoked invasion of Ukraine and the global rally in support of Ukraine. The U.S. government, along with its allies and partners, have put into place in unprecedented speed a comprehensive set of economic sanctions. It has been remarkable to follow.
Given these actions, it is not surprising that DOJ and OFAC would follow up with an aggressive enforcement program. Frankly, the foundation for aggressive enforcement has been built over the past few years. We have highlighted in past blog…
