Volkov Law – This case underscores the risks that U.S. companies or foreign subsidiaries face when pursuing opportunities with third parties that act on behalf of their company, as well as the need for controls to prevent employees from breaching sanctions compliance controls.
The Justice Department has touted the upcoming wave of corporate prosecutions for criminal sanctions violation as the era of “The New FCPA.” DOJ’s reference is intended to communicate a strong message—companies are going to be prosecuted for sanctions violations, akin to FCPA prosecutions where companies are required to pay a fine, and enter a guilty or a deferred or non-prosecution agreement. DOJ is backing up its warning by assigning 25 new prosecutors to the National Security Division to work on corporate sanctions prosecutions.
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