- 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 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.
Global sanctions rules are increasing rapidly, as are tools to detect and punish those who break them. In response, the U.K. government is creating a new Office of Trade Sanctions Implementation to investigate and penalize those who break sanctions rules.
Five individuals and seven entities in Iran, China, and Hong Kong have been targeted for U.S. sanctions by the Treasury Department’s Office of Foreign Assets Control for helping to obtain components used in Iran’s missles and drones.
