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Monaco Takes Aim at Economic Sanctions Evasion with New DOJ Initiatives

Strengthening Enforcement of Economic Sanctions and Export Control Violations

On March 2, 2023, the Department of Justice (DOJ) announced several new initiatives aimed at strengthening enforcement of economic sanctions and export control violations. The push, led by Deputy Attorney General Lisa Monaco, seeks to address what she described as a “troubling trend” - the intersection of corporate crime and national security.

Companies at the Front Lines of National Security

According to Monaco, companies are now at the forefront of today’s geopolitical and national security challenges. She noted that corporate criminal investigations often carry profound national security implications, particularly in light of recent geopolitical events that have elevated the importance of sanctions and export control enforcement.

Key Themes in Sanctions Enforcement

Monaco reiterated two key themes when discussing sanctions enforcement:

• Sanctions as the “new FCPA”: Emphasizing DOJ’s commitment to prioritizing sanctions enforcement similar to its efforts under the Foreign Corrupt Practices Act.
• Industry-wide impact: Noting that sanctions issues impact a wide range of industries, no longer limited to financial services.

Expanding National Security Division

To support this increased emphasis on investigating and enforcing sanctions violations by companies outside of financial services, DOJ will be adding more than twenty-five new prosecutors to its National Security Division. The hiring spree includes the division’s first-ever Chief Counsel for Corporate Enforcement.

Substantial Investment in Bank Integrity Unit (BIU)

The department will also be making a “substantial investment” in the BIU of the Criminal Division’s Money Laundering and Asset Recovery Section, which has a significant track record of prosecuting global financial institutions for sanctions violations.

Updated Enforcement Policy

In related news, the National Security Division recently published an updated enforcement policy for business organizations. While the policy now notes that it will inform all corporate criminal matters handled by the division, it is “most applicable” to self-disclosures of potential criminal violations of export and sanctions laws.

Presumption of Cooperation

The presumption established in the December 2019 version of the policy that a company will receive a non-prosecution agreement if it makes a voluntary self-disclosure, fully cooperates, and timely and appropriately remediates remains in place.

Joint Compliance Guidance

Finally, Monaco announced that the National Security Division would begin issuing joint advisories with the Commerce and Treasury Departments to provide information about enforcement trends and convey expectations regarding national security-related compliance. The first compliance note focuses on the use of third-party intermediaries or transshipment points to circumvent restrictions and obscure the true identities of Russian end users.

Implementing Compliance Controls

The joint notice encourages businesses to implement rigorous compliance controls, including:

• Screening current and new customers against the Consolidated Screening List
• OFAC Sanctions Lists