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Department of Justice Initiatives Prioritize Economic Sanctions Enforcement

On March 2, 2023, the Department of Justice announced several new initiatives that prioritize the investigation and enforcement of economic sanctions evasion, export control violations, and similar economic crimes.  Deputy Attorney General Lisa Monaco announced a “surge of resources to address a troubling trend: the intersection of corporate crime and national security.”  In particular, DOJ’s … Continue Reading

Increasing US Enforcement Action for Sanctions Violations by Crypto Exchanges Likely to Have Ripple Effect in UK and Europe

The investigation and enforcement of potential sanctions violations by crypto exchanges is an area of focus in the US at present.  The US Department of the Treasury’s Office of Foreign Assets Control’s (OFAC) recent settlement with Kraken, a global virtual currency exchange, is the most recent OFAC case demonstrating the risks for virtual currency platforms … Continue Reading

OFAC Sanctions Virtual Currency Mixer “Tornado Cash”

On August 8, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned virtual currency mixer Tornado Cash for having laundered more than USD 7 billion worth of virtual currency since its founding in 2019.  This includes over USD 455 million worth of stolen virtual currency associated with the Lazarus Group, … Continue Reading

Russian Sanctions Update: Will “Biting” Eighth EU Sanctions Package Prohibit Legal Services?

“Russia should not benefit from European knowledge and expertise.”  That is the view of European Commission (“EC”) President Ursula von der Leyen, who recently proposed an eighth package of sanctions against Russia in response to “escalation” in Ukraine.  Among the “biting” new sanctions will be a wider ban on the provision of European services to … Continue Reading

The UK’s OFSI Provides Guidance on Strict Liability Sanctions Breach Penalties

The Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, which is the authority for implementing financial sanctions in the UK, have published guidance to clarify how they will use their new powers to impose civil monetary penalties for sanctions breaches on a strict liability basis from Monday 15 June 2022.  The full message … Continue Reading

Rare Due Process Reprieve for Company Penalized by OFAC for Violating Ukraine Sanctions

Following a ruling issued last week by a federal judge in Texas, ExxonMobil Corporation (“ExxonMobil”) will not have to pay a previously issued penalty for contracting with Russia’s state-owned PJSC Rosneft Oil Company (“Rosneft”), since it was not provided fair notice by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) that … Continue Reading

Russian Duma Revisits Criminalization as Counter-sanction

Russian Duma Revisits Criminalization as Counter-sanction The Russian Duma is considering a bill that would prohibit media communications that reveal non-compliance with sanctions or facilitate imposition of sanctions and would also impose criminal penalties on those that disclose or transfer information to organizations “directly or indirectly” under the control of an “unfriendly state”, any company … Continue Reading

Anti-Corruption Guidance in Russia: What’s a Company to Do?

Anti-corruption has been a hot topic in Russia for some time. But recently, the Russian government has begun to take creative approaches in the fight against corruption. These initiatives are aimed at raising public awareness of corruption among the general public. What appears to be missing in this outreach is compliance guidance to companies in … Continue Reading
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