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In a May 12, 2025 speech that signaled both a recalibration of and recommitment to prosecuting white-collar crime, Matthew R. Galeotti, the newly appointed Head of the Department of Justice’s Criminal Division, said that the Division is “turning a new page” and embracing an enforcement approach that aims to elevate efficiency, predictability, and fairness. The…

On October 4, 2023, Deputy Attorney General (DAG) Lisa O. Monaco announced the Department of Justice’s (DOJ) new safe harbor policy for voluntary self-disclosures made in connection with mergers and acquisitions (Safe Harbor Policy).

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  • Key takeaway #1 Companies should be mindful that the U.S. agencies responsible for civil and criminal export controls and sanctions compliance maintain separate VSD policies. This announcement highlights key aspects of each VSD policy.
  • Key takeaway #2 Failure to initiate an internal investigation promptly after discovering a potential export controls or sanctions
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On February 24, 2023, the United States and other G7 nations announced a number of new sanctions and export control measures coinciding with the one-year mark of Russia’s military invasion of Ukraine. Shortly after these expansive sanctions and export controls were announced, the Departments of Justice (“DOJ”), the Treasury (“Treasury”), and Commerce (“Commerce”) issued their…

Last week the U.S. Department of Justice (“DOJ”) and U.S. Department of Commerce announced a new Disruptive Technology Strike Force (the “DIS-TECH Strike Force”). The Strike Force will bring together experts throughout government – including the Federal Bureau of Investigation (“FBI”), Homeland Security Investigations (“HSI”), and 14 U.S. Attorneys’ Offices in 12 metropolitan regions across…

On October 28, Deputy Attorney General (“DAG”) Lisa O. Monaco delivered remarks at the ABA’s 36th National Institute on White Collar Crime. Department of Justice (“DOJ” or “Department”) officials have recently referenced the coming enforcement “surge,” and the DAG’s remarks last week provide a roadmap to corporate criminal enforcement under the current…

After a predictable lull in corporate enforcement actions during the recent transition between administrations, and following a near quarter-century low in such actions under the previous administration, the Department of Justice (“DOJ”) announced this week that a “surge” of corporate enforcement is coming. Recent comments from DOJ officials indicate that, in addition to a significant…