- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Kyle Brasseur2023-07-14T19:15:00
When Deputy Attorney General Lisa Monaco first described sanctions as “the new FCPA,” the risk landscape changed.
The idea of the Department of Justice (DOJ) scrutinizing sanctions on par with how it views bribery and corruption under the Foreign Corrupt Practices Act alters the calculus of whether a company should voluntarily self-disclose potential violations.
“Part of what’s so scary about this for companies and in-house compliance professionals is that sanctions have traditionally been strict liability,” said Jessica Sanderson, partner at Volkov Law Group, during a panel discussion at Compliance Week’s Third-Party Risk Management Summit in Atlanta. “You don’t really need to know that you’re violating the law to be held responsible—at least for the administrative penalties.”
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The Department of Justice’s push to incentivize companies to voluntarily self-disclose potential misconduct reached its next stage in the form of a safe harbor policy regarding mergers and acquisitions.
The Department of Justice announced new positions in its National Security Division to support the agency’s crackdown on sanctions evasion, export control violations, and other forms of economic crime.
Freedom Holding Corp. was accused of “brazen sanctions evasion,” along with openly flouting anti-money laundering and know your customer regulations, as part of an investigative report published by short seller Hindenburg Research.
The EU and U.K. have rushed to commit themselves to intensifying action on sanctions evasion after U.S. President-elect Donald Trump’s victory, but any compliance managers who believe Trump will make global sanctions compliance easier in 2025 are likely to be disappointed.
With a new political regime ready to take over in the U.S., the effectiveness of sanctions against malign foreign actors like Russia, North Korea, and Iran have come into question. While the European Union and U.K. have increased sanctions pressure, critics have publicly asked: Is it enough?
The U.K. has issued 56 new sanctions against entities and individuals involved with Russia’s war effort, including several private mercenary groups operating in Africa that are connected to the Kremlin.
