Recent Subpoenas Highlight DOJ Focus on Corporate Sanctions Enforcement, Law Firm Says
DOJ’s recent sanctions-related subpoenas of Credit Suisse Group and UBS Group are more evidence of the agency’s increasing “emphasis” on corporate enforcement, Rahman Ravelli said in an April 6 client alert. The agency launched a probe on both Swiss banks to examine whether they helped Russian oligarchs evade sanctions, Bloomberg reported last month, and Rahman Ravelli said the effort is part of a “wave of subpoenas” issued by DOJ in recent weeks.
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The firm said DOJ is “looking to assess which bank employees dealt with sanctioned clients, how such clients were vetted and whether any laws were broken.” The agency’s focus on “identifying and assessing the relationships between bank employees and sanctioned clients shows how much emphasis the authorities are now putting on individuals’ accountability when it comes to corporate enforcement,” Rahman Ravelli said. “The DOJ approach has made sanctions the latter-day equivalent of the Foreign Corrupt Practices Act -- and companies have to ensure that their approach to compliance recognises and reflects this.”
DOJ recently announced it’s hiring 25 new export control and sanctions prosecutors (see 2303070023), and the Bureau of Industry and Security said it plans to increase the number of penalties it issues this year against corporations for export violations (see 2303030035 and 2303200051).