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The U.S. Department of Justice has declared sanctions to be the “new FCPA.” This is not just rhetoric; there are tectonic shifts already underway in how the U.S. government prosecutes sanctions evasion and what it expects from corporate compliance departments—who are caught in the middle between American and European national security priorities and increasing sophisticated evasion by adversaries.
Join Michael H. Huneke of Hughes Hubbard & Reed LLP and Jonathan Cross of Herbert Smith Freehills LLP in this CLE webcast to learn what these changes mean and practical tips for responding to them.
Key topics include:
- Recent Legal Developments & Their Practical Significance
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- Executive Order 14114’s secondary sanctions for FFIs facilitating provision of certain goods/services to Russia.
- Need for non-US companies to adopt or enhance US export control policies, esp. given “Foreign Direct Product” rules re Russia/China
- Growing complexity of “targeted” PRC sanctions (e.g., CMIC restrictions, US outbound investment restrictions, export control tightening, US import and public procurement restrictions)
- Recent Enforcement Trends & Key Takeaways
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- Recent enforcement focus on fintech and crypto
- DOJ has declared sanctions to be the “new FCPA.” What does that mean, and what are the implications?
- BIS recently sent several dozen American companies “red flag” letters listing third parties involved in diversity components to Russia. What is the significance of these letters, especially regarding those companies’ awareness of evasion or diversion?
- Recent enforcement focus on export control evasion: What are the noteworthy enforcement actions since February 2022, and what are the key practical takeaways for compliance teams?